Paul W. Oosterhuis (Skadden, Washington, D.C.) has published the 2006 Laurence Neal Woodworth Memorial Lecture on Federal Tax Law and Policy, The Evolution of International Tax Policy — What Would Larry Say?, 33 Ohio N.U. L. Rev. 1 (2007).  Here is part of the conclusion:

What can we learn from Larry Woodworth’s perspective in thinking about international tax reform today? In the end I think we can learn two things. While we are considering legislative proposals for further cutbacks to subpart F, we should not lose sight of its original practical wisdom — that subjecting earnings stripping transactions to subpart F may significantly reduce incentives for foreign versus U.S. investment without burdening U.S. multinationals compared to either local competitors or multinational competitors from most major countries. Moreover, particularly if substantial deferral planning is continued to be permitted, we should seriously consider moving to a territorial system to avoid the need for a periodic HIA to deal with the substantial imbalance of funds abroad. I cannot say that I know Larry would agree with these thoughts. He was a master at concealing his own views. But I do know he would want to make sure that Congress carefully considered all of the issues relevant to these proposals and was fully aware of the consequences of the decisions it ultimately makes. That was his ultimate genius and one of the reasons why we honor him today.