Robert J. Peroni

Robert J. Peroni: Publications

• article

  Incorporating a Minimum Tax in a Territorial System

  TAX NOTES

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen Shay

  2017

  Links for this publication:

• book

  Federal Income Taxation: Code and Regulations--Selected Sections

  CCH Inc.

  Authors:

  2017-2018

  Links for this publication:

• book

  Oil and Gas Law and Taxation

  West Academic Publishing

  Authors:

  Owen L. Anderson, John S. Dzienkowski, Robert J. Peroni, Ernest E. Smith III, J. Lowe, D. Pierce

  2017

  Links for this publication:

• article

  Getting From Here to There: The Transition Tax Issue

  TAX NOTES

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen Shay

  2017

  Links for this publication:

• article

  Two Cheers for the Foreign Tax Credit, Even in the BEPS Era

  Tulane Law Review

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2016

  Links for this publication:

• article

  R&D Tax Incentives: Growth Panacea or Budget Trojan Horse?

  Tax Law Review

  Authors:

  Robert J. Peroni, Stephen E. Shay & J. Clifton Fleming, Jr.

  2016

  Links for this publication:

• book

  Federal Income Tax: Code and Regulations, Selected Sections

  Authors:

  Robert J. Peroni, Martin B. Dickinson ed.

  August 1, 2016

  Links for this publication:

• book

  International Income Taxation: Code and Regulations, Selected Sections

  Wolters Skluwer

  Authors:

  Robert J. Peroni, Richard Crawford Pugh & Charles H. Gustafson

  2016-2017 and 2017-2018

  Links for this publication:

• article

  The Decline in Tax Adviser Professionalism in American Society

  Fordham Law Review

  Authors:

  John S. Dzienkowski, Robert J. Peroni

  2016

  Links for this publication:

• article

  Treasury’s Unfinished Work on Corporate Expatriations

  Tax Notes 933 (2016) (with J. Clifton Fleming, Jr. & Stephen Shay). [Reprinted in 81 Tax Notes International

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen Shay

  2016

  Links for this publication:

• article

  Defending Worldwide Taxation with a Shareholder-Based Definition of Corporate Residence

  BYU L. REV.

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen Shay

  2016

  Links for this publication:

• article

  Designing a 21st Century Corporate Tax—An Advance U.S. Minimum on Foreign Income and Other Measures to Protect the Base

  Florida Tax Review

  Authors:

  Robert J. Peroni, Stephen E. Shay & J. Clifton Fleming, Jr.

  2015

  Links for this publication:

• article

  Getting Serious about Cross-Border Earnings Stripping: Establishing an Analytical Framework

  North Carolina Law Review

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2015

  Links for this publication:

• book

  U.S. International Taxation

  Authors:

  Robert J. Peroni, Joel D. Kuntz

  2015

  Links for this publication:

• article

  Formulary Apportionment in the U.S. International Income Tax System: Putting Lipstick on a Pig?

  Michigan Journal of International Law

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2014

  Links for this publication:

• article

  A Hitchhiker's Guide to Outbound International Tax Reform

  Chapman Law Review

  Authors:

  2014

  Links for this publication:

• article

  Territoriality in Search of Principles and Revenue: Camp and Enzi

  Tax Notes 173 (2013) (with J. Clifton Fleming, Jr. & Stphen Shay). [Reprinted in 72 Tax Notes International

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stphen Shay

  2013

  Links for this publication:

• book

  Taxation of Business Enterprises

  Authors:

  Robert J. Peroni, Steven A. Bank

  2012

  Links for this publication:

• book

  Federal Income Tax: Doctrine, Structure, and Policy

  Authors:

  Robert J. Peroni, Joseph M. Dodge & J. Clifton Fleming, Jr.

  2012

  Links for this publication:

• article

  Designing a U.S. Exemption System for Foreign Income When the Treasury is Empty

  Florida Tax Review

  Authors:

  2012

  Links for this publication:

• book

  Taxation of International Transactions: Materials, Text and Problems

  Authors:

  Robert J. Peroni, Charles H. Gustafson & Richard Crawford Pugh

  2011

  Links for this publication:

• article

  Can Tax Expenditure Analysis Be Divorced from a Normative Tax Base? A Critique of the "New Paradigm" and Its Denouement

  Virginia Tax Review

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr.

  2010

  Links for this publication:

• article

  Perspective on the Worldwide vs. Territorial Taxation Debate

  Tax Notes 1079 (2009) (with J. Clifton Fleming, Jr. & Stephen E. Shay). [Reprinted in 57 Tax Notes International

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2010

  Links for this publication:

• article

  Worse than Exemption

  Emory Law Journal

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2009

  Links for this publication:

• article

  Conflicts of Interest in Lawyer Referral Arrangements with Nonlawyer Professional

  The Georgetown Journal of Legal Ethics

  Authors:

  John S. Dzienkowski, Robert J. Peroni

  2008

  Links for this publication:

• article

  Reinvigorating Tax Expenditure Analysis and Its International Dimension

  Virginia Tax Review

  Authors:

  Robert J. Peroni, with J. Clifton Fleming, Jr.

  2008

  Links for this publication:

• article

  Conflicts of Interest in Lawyer Referral Arrangements with Nonlawyer Professionals

  The Georgetown Journal of Legal Ethics

  Authors:

  2008

  Links for this publication:

• article

  Some Perspectives from the United States on the Worldwide Taxation vs. Territorial Taxation Debate

  Journal of the Australasian Tax Teachers Association

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2008

  Links for this publication:

• book

  Taxation of Business Enterprises: Cases and Materials

  Authors:

  Robert J. Peroni, Steven A. Bank & Glenn E. Coven

  2006

  Links for this publication:

• article

  Recent Developments in the Taxation of Corporations and Shareholders: Pt. 2

  Authors:

  June 1, 2005

  Links for this publication:

• article

  Recent Developments in the Taxation of Corporations and Shareholders: Pt. 1

  Authors:

  April 1, 2005

  Links for this publication:

• article

  Exploring the Contours of a Proposed U.S. Exemption (Territorial) Tax System

  Tax Notes 1557 (2005) (with J. Clifton Fleming, Jr.). [Reprinted in 41 Tax Notes International

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr.

  2006

  Links for this publication:

• article

  Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax--What's ETI Repeal Got To Do With It?

  Tax Notes 1393 (2004) (with J. Clifton Fleming, Jr.). [Reprinted in 35 Tax Notes International

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr.

  2004

  Links for this publication:

• article

  Tax Reform Interrupted: The Chaotic State of Tax Policy in 2003

  McGeorge Law Review

  Authors:

  2004

  Links for this publication:

• book

  Hemingway Oil and Gas Law and Taxation

  St. Paul: Thomson/West

  Authors:

  Owen L. Anderson, John S. Dzienkowski, Robert J. Peroni, Ernest E. Smith III, John S. Lowe, David E. Pierce

  2004

  Links for this publication:

• article

  Reform and Simplification of the U.S. Foreign Tax Credit Rules

  Tax Notes 103 (2003) (with J. Clifton Fleming, Jr. & Stephen E. Shay). [Reprinted in 31 Tax Notes International

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2003

  Links for this publication:

• article

  Commentator: Response to Professor McDaniel's Article [Stephen L. Cantor International Tax Symposium]

  George Washington International Law Review

  Authors:

  2003

  Links for this publication:

• article

  A Hitchhiker's Guide to Reform of the Foreign Tax Credit Limitation

  SMU Law Review

  Authors:

  2003

  Links for this publication:

• article

  The David R. Tillinghast Lecture: "What's Source Got to Do With It?"--Source Rules and U.S. International Taxation

  Tax Law Review

  Authors:

  Robert J. Peroni, Stephen E. Shay & J. Clifton Fleming, Jr.

  2002

  Links for this publication:

• article

  The Decline in Lawyer Independence: Lawyer Equity Investments in Clients

  Texas Law Review

  Authors:

  2002

  Links for this publication:

• article

  Point: The United States Should Tax U.S. Corporations on Their Worldwide Income

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2001

  Links for this publication:

• article

  Deferral of U.S. Tax on International Income: End It, Don't Mend It--Why Should We Be Stuck in the Middle with Subpart F?

  Texas Law Review

  Authors:

  2001

  Links for this publication:

• article

  Fairness in International Taxation: The Ability-to-Pay Case for Taxing Worldwide Income

  Florida Tax Review

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2001

  Links for this publication:

• article

  Reform in the Use of Phaseouts and Floors in the Individual Income Tax System

  Tax Notes 1

  Authors:

  2001

  Links for this publication:

• article

  The Proper Approach to Taxing the Income of Foreign Controlled Corporations

  Brooklyn Journal of International Law

  Authors:

  2001

  Links for this publication:

• article

  An Alternative View of Deferral: Considering a Proposal to Curtail, Not Expand, Deferral

  Tax Notes International 525 (2000) (with J. Clifton Fleming, Jr. & Stephen E. Shay). [Reprinted in 86 Tax Notes

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  2000

  Links for this publication:

• article

  Multidisciplinary Practice and the American Legal Profession: A Market Approach to Regulating the Delivery of Legal Services in the Twenty-First Century

  Fordham Law Review

  Authors:

  John S. Dzienkowski, Robert J. Peroni

  2000

  Links for this publication:

• article

  Shaping the Future of Law: ABA's Multidisciplinary Practice Proposals Will Stymie the Growth of MDPs

  Legal Times, Aug. 2, 1999, at 27 [Reprinted in Texas Lawyer]

  Authors:

  John S. Dzienkowski, Robert J. Peroni

  Aug. 9, 1999

  Links for this publication:

• article

  ABA's Definition of Practice Flawed

  National Law Journal

  Authors:

  John S. Dzienkowski, Robert J. Peroni

  July 26, 1999

  Links for this publication:

• article

  Getting Serious About Curtailing Deferral of U.S. Tax on Foreign Source Income

  SMU Law Review

  Authors:

  Robert J. Peroni, J. Clifton Fleming, Jr. & Stephen E. Shay

  1999

  Links for this publication:

• article

  MDP Commission Opts for Expanded Regulation and Economic Protectionism

  Authors:

  1999

  Links for this publication:

• book

  Cases and Materials on Taxation of Business Enterprises

  Authors:

  Robert J. Peroni, B.B. Barton, G.E. Coven, & R.C. Pugh

  1998

  Links for this publication:

• article

  A Response to Dean Thompson's Paper on the Impact of Code Section 367 and the European Union's 1990 Council Directive on Tax-Free Cross-Border Mergers and Acquisitions

  University of Cincinnati Law Review

  Authors:

  1998

  Links for this publication:

• article

  Back to the Future: A Path to Progressive Reform of the U.S. International Income Tax Rules

  University of Miami Law Review

  Authors:

  1997

  Links for this publication:

• book

  Taxation of Business Enterprises

  Authors:

  Robert J. Peroni, B.B. Barton, G.E. Coven, & R.C. Pugh

  1995

  Links for this publication:

• article

  Natural Resources Taxation: 1992--The Year in Review

  Natural Resources Tax Review

  Authors:

  John S. Dzienkowski, Robert J. Peroni

  1993

  Links for this publication:

• article

  The Energy Policy Act of 1992 and Its Impact on the Law of Natural Resources Taxation

  Natural Resources Tax Review

  Authors:

  1993

  Links for this publication:

• article

  Taxing and Subsidizing Natural Resource Development

  Natural Resources Tax Review

  Authors:

  1993

  Links for this publication:

• article

  A Brief Critique of the Supreme Court's Opinion in the Hill Case

  Natural Resources Tax Review

  Authors:

  1993

  Links for this publication:

• article

  Combining Timber Properties for Depletion Purposes: The Tax Court's Decision in RLC Industries Co. v. Commissioner

  Natural Resources Tax Review

  Authors:

  1992

  Links for this publication:

• article

  Phillips Petroleum Co. v. Commissioner: An Important Decision for the Natural Resource Operator Engaged in Multinational Operations

  Natural Resources Tax Review

  Authors:

  1992

  Links for this publication:

• article

  A Critical View of Zuhone's Pool of Capital Dicta

  Natural Resources Tax Review

  Authors:

  1991

  Links for this publication:

• article

  A Critical View of the Hill Decisions: Calculating Excess Depletion Under the Alternative Minimum Tax

  Natural Resources Tax Review

  Authors:

  1991

  Links for this publication:

• article

  Significant Current Developments in Oil and Gas Taxation

  Authors:

  1989

  Links for this publication:

• article

  A Policy Critique of the Section 469 Passive Loss Rules

  Southern California Law Review

  Authors:

  1988

  Links for this publication:

• book

  Natural Resource Taxation: Principles and Policies

  Authors:

  1988

  Links for this publication:

• article

  Untangling the Web of Gift-Leaseback Jurisprudence

  Minnesota Law Review

  Authors:

  1984

  Links for this publication:

• article

  Selecting an Enforceable Forum Selection Clause

  Corporate Law Review

  Authors:

  Robert J. Peroni, J. Fretty

  1978

  Links for this publication: