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Avi-Yonah Posts Seven Tax Papers On SSRN

Reuven S. Avi-Yonah (Michigan; Google Scholar) has posted seven tax papers on SSRN:

SSRN Logo (2018)The Up-C, Taxation, and Corporate Governance, 184 Tax Notes Fed. 2493 (Sept. 23, 2024): 

This paper examines the tax and corporate governance issues of umbrella partnership C corporations and considers policy proposals to address those concerns.

Crypto and the Exit Tax, 184 Tax Notes Fed. 2143 (Sept. 9, 2024):

This paper discusses the Ver case and its implications for a constitutional challenge to section 877A.

Sourcing Derivatives: Time to Reverse the Rule?, 184 Tax Notes Fed. 1993 (Sept. 2, 2024):

This paper responds to a recent article on the application of withholding taxes on derivatives and questions the current state of U.S. rules.

Once More: Digital Services Taxes Should Be Creditable, 184 Tax Notes Fed. 1707 (Aug. 26, 2024):

This paper responds to critiques of the creditability of Digital Services Taxes.

The Usefulness of Pillar One, 184 Tax Notes Fed. 1521 (Aug. 19, 2024): 

This paper argues that despite the impending collapse of pillar 1 the exercise was useful.

Limitation on Benefits or Principal Purpose Test? Part 1, 184 Tax Notes Fed. 1109 (Aug. 5, 2024): 

This paper examines the relationship between the principal purpose test and the limitation on benefits provision.

Limitation on Benefits or Principal Purpose Test? Part 2, 184 Tax Notes Fed. 1309 (Aug. 12, 2024): 

This paper examines the relationship between the principal purpose test and the limitation on benefits provision.

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