Robert J. Peroni
- The Fondren Foundation Centennial Chair for Faculty Excellence
- Professor
Featured Work
Professor Peroni currently holds the Fondren Foundation Centennial Chair for Faculty Excellence. He joined the Texas faculty in 2003 and his primary areas of teaching and scholarship are federal income taxation, international taxation, natural resource taxation, and professional responsibility/legal ethics. He is one of the nation's top scholars in international taxation and in energy taxation. He is a co-author of six books and has written many articles on taxation and professional responsibility topics. He has presented papers and given lectures throughout the world and was a frequent teacher of tax law courses in the former NYU/IRS Continuing Professional Education Program in Washington, D.C. In 2006, he was the recipient of the Texas Exes Faculty Teaching Award for excellence in teaching. He is the co-chair of the advisory boards for two recurring programs co-sponsored by the IRS the Biennial Parker Fielder Oil and Gas Tax Conference, co-sponsored by the IRS with the University of Texas School of Law, and the Annual Institute on Current Issues in International Taxation, co-sponsored by the IRS with the George Washington University Law School. During the 1985-86 academic year, he was a Professor-in-Residence in the Office of Chief Counsel of the IRS in Washington, D.C., and, during the 2000-2001 academic year, he was one of the Academic Advisors to the Joint Committee on Taxation's Study of the Overall State of the Federal Tax System. He has been active on several committees of the American Bar Association's Section of Taxation and has served as the Chair of the Taxation Section of the Association of American Law Schools. He is a Fellow of the American College of Tax Counsel.
Prior to joining the Texas faculty, Professor Peroni taught at the Tulane University School of Law in New Orleans, from 1981-1989, and at the George Washington University Law School in Washington, D.C., from 1989-2003, where he was the Robert Kramer Research Professor of Law. He was the first recipient of Tulane's Felix Frankfurter Distinguished Teaching Award, and he twice received G.W.'s Distinguished Faculty Service Award, selected by the vote of G.W. Law School graduating classes. He also has taught as a visiting professor on the law faculties of New York University, the University of Texas, UCLA, the University of Pennsylvania, Northwestern University, and Georgetown University. He was the J. Landis Martin Visiting Professor of Law and Business at Northwestern during the 2002-03 academic year and was the Jack N. Pritzker Distinguished Visiting Professor of Law at Northwestern during the Fall 2006 semester. He was the Parker C. Fielder Regents Professor in Tax Law at the University of Texas from 2003-2005, and the James A. Elkins Centennial Chair in Law from 2005-2010.
Professor Peroni's publications include the three-volume treatise (formerly co-authored with Joel Kuntz and now co-authored with John Bogdanski), U.S. International Taxation, a leading casebook on natural resource taxation, Natural Resource Taxation Principles and Policies (co-authored with John Dzienkowski), the widely used casebook on international taxation, Taxation of International Transactions (currently co-authored with Karen Brown and Cliff Fleming), Taxation of Business Enterprises (currently co-authored with Steven Bank), a federal income taxation casebook, Federal Income Tax: Doctrine, Structure, and Policy (currently co-authored with Joseph Dodge, Cliff Fleming, and Francine Lipman), and Oil and Gas Law and Taxation (2d ed. 2023) (co-authored with Owen Anderson, John Dzienkowski, and John Lowe). His law review articles include Directions for U.S. International Tax Policy, A Response to Hanna and Wilson, 48 J. CORP. L. DIGITAL 8 (2023) (co-authored with Cliff Fleming and Steve Shay), Viewing the GILTI Tax Rates Through a Tax Expenditure Lens, 177 TAX NOTES FED. 1525 (2022) (co-authored with Cliff Fleming and Steve Shay), Why R&D Should be Allocated to Subpart F and GILTI, 167 TAX NOTES FED. 2081 (2020) (co-authored with Reuven Avi-Yonah, Patrick Driessen, Cliff Fleming, and Steve Shay), Expanded Worldwide Versus Territorial Taxation After the TCJA, 161 TAX NOTES 1173 (2018) (co-authored with Cliff Fleming and Steve Shay), Incorporating a Minimum Tax in a Territorial System, 157 TAX NOTES 73 (2017) (co-authored with Cliff Fleming and Steve Shay), Getting From Here to There: The Transition Tax Issue, 155 TAX NOTES 69 (2017) (co-authored with Cliff Fleming and Steve Shay), Defending Worldwide Taxation with a Shareholder-Based Definition of Corporate Residence, 2016 BYU L. REV. 1681 (2016) (co-authored with Cliff Fleming and Steve Shay), Two Cheers for the Foreign Tax Credit, Even in the BEPS Era, 91 TUL. L. REV. 1 (2016) (recipient of the John Minor Wisdom Award for Academic Excellence in Legal Scholarship for Volume 91 of the Tulane Law Review) (co-authored with Cliff Fleming and Steve Shay), R&D Tax Incentives: Growth Panacea or Budget Trojan Horse, 69 TAX L. REV. 419 (2016) (co-authored with Cliff Fleming and Steve Shay), The Decline in Tax Adviser Professionalism in American Society, 84 FORDHAM L. REV. 2721 (2016) (co-authored with John Dzienkowski), Treasury's Unfinished Work on Corporate Expatriations, 150 TAX NOTES 933 (2016) (also published in 81 TAX NOTES INT'L 673 (2016)) (co-authored with Cliff Fleming and Steve Shay), Designing a 21st Century Corporate Tax--An Advance U.S. Minimum Tax on Foreign Income and Other Measures to Protect the Base, 17 FLA. TAX REV. 669 (2015) (co-authored with Cliff Fleming and Steve Shay), Getting Serious About Cross-Border Earnings Stripping: Establishing an Analytical Framework, 93 N.C.L. REV. 673 (2015) (co-authored with Cliff Fleming and Steve Shay), Formulary Apportionment in the U.S. International Income Tax System: Putting Lipstick on a Pig?, 36 MICH. J. INT'L L. 1 (2014) (co-authored with Cliff Fleming and Steve Shay), A Hitchhiker's Guide to Outbound International Tax Reform, 18 CHAP. L. REV. 133 (2014) (co-authored with Cliff Fleming), Territoriality in Search of Principles and Revenue: Camp and Enzi, 141 TAX NOTES 173 (2013) (also published in 72 TAX NOTES INT'L 155 (2013)) (co-authored with Cliff Fleming and Steve Shay), Designing a U.S. Exemption System for Foreign Income When the Treasury Is Empty, 13 FLA. TAX REV. 397 (2012) (co-authored with Cliff Fleming and Steve Shay), Can Tax Expenditure Analysis Be Divorced From a Normative Tax Base?: A Critique of the “New Paradigm” and Its Denouement, 30 VA. TAX REV. 135 (2010) (co-authored with Cliff Fleming), Worse Than Exemption, 59 EMORY L.J. 79 (2009) (co-authored with Cliff Fleming and Steve Shay), Perspectives on the Worldwide vs. Territorial Taxation Debate, 125 TAX NOTES 1079 (2009) (co-authored with Cliff Fleming and Steve Shay), Reinvigorating Tax Expenditure Analysis and Its International Dimension, 27 VA. TAX REV. 437 (2008) (co-authored with Cliff Fleming), Conflicts of Interest in Lawyer Referral Arrangements with Nonlawyer Professionals, 21 GEO. J. LEGAL ETHICS 197 (2008) (co-authored with John Dzienkowski), Exploring the Contours of a Proposed U.S. Exemption (Territorial) System, 109 TAX NOTES 1557 (2005) (also published in 41 TAX NOTES INT'L 217 (2006)) (co-authored with Cliff Fleming), What's Source Got to Do With It? Source Rules and U.S. International Taxation, 56 TAX L. REV. 81 (2002) (co-authored with Steve Shay and Cliff Fleming), The Decline in Lawyer Independence: Lawyer Equity Investments in Clients, 81 TEX. L. REV. 405 (2002) (co-authored with John Dzienkowski), and 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, 79 TEX. L. REV. 1609 (2001).
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year-2009
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Book
International Income Taxation: Code and Regulations--Selected Sections
Robert J. Peroni. International Income Taxation: Code and Regulations--Selected Sections (edited by Robert J. Peroni, Coordinating Editor. CCH Inc., 2009-2010). -
Book
Federal Income Taxation: Code and Regulations--Selected Sections
Robert J. Peroni. Federal Income Taxation: Code and Regulations--Selected Sections (edited by Robert J. Peroni, Contributing Editor. CCH Inc., 2009-2010). -
Article
Worse than Exemption
Robert J. Peroni, Worse than Exemption, 59 Emory Law Journal 70 (2009) (with J. Clifton Fleming, Jr. & Stephen E. Shay). [Reprinted in 2 International Tax Law 198 (Reuven S. Avi-Yonah, ed.; Northampton, MA : Edward Elgar Publishing, 2016.]
year-2008
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Article
Conflicts of Interest in Lawyer Referral Arrangements with Nonlawyer Professional
John S. Dzienkowski, Conflicts of Interest in Lawyer Referral Arrangements with Nonlawyer Professionals, 21 The Georgetown Journal of Legal Ethics 197 (2008) (with Robert J. Peroni). -
Article
Conflicts of Interest in Lawyer Referral Arrangements with Nonlawyer Professionals
Robert J. Peroni, Conflicts of Interest in Lawyer Referral Arrangements with Nonlawyer Professionals, 21 The Georgetown Journal of Legal Ethics 197 (2008) (with John S. Dzienkowski). -
Article
Some Perspectives from the United States on the Worldwide Taxation vs. Territorial Taxation Debate
Robert J. Peroni, Some Perspectives from the United States on the Worldwide Taxation vs. Territorial Taxation Debate, 3 Journal of the Australasian Tax Teachers Association 35 (2008) (with J. Clifton Fleming, Jr. & Stephen E. Shay). -
Article
Reinvigorating Tax Expenditure Analysis and Its International Dimension
Robert J. Peroni, Reinvigorating Tax Expenditure Analysis and Its International Dimension, 27 Virginia Tax Review 437 (2008) (with J. Clifton Fleming, Jr.).
year-2006
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Book
Taxation of Business Enterprises: Cases and Materials
Robert J. Peroni, Taxation of Business Enterprises: Cases and Materials (St. Paul, MN: Thomson/West, 3rd ed. 2006) (with Steven A. Bank & Glenn E. Coven).
year-2005
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Article
Recent Developments in the Taxation of Corporations and Shareholders: Pt. 2
Robert J. Peroni, Recent Developments in the Taxation of Corporations and Shareholders: Pt. 2, Corporate Taxation, May/June 2005, at 23. -
Article
Recent Developments in the Taxation of Corporations and Shareholders: Pt. 1
Robert J. Peroni, Recent Developments in the Taxation of Corporations and Shareholders: Pt. 1, Corporate Taxation, Mar./Apr. 2005, at 3. -
Article
Exploring the Contours of a Proposed U.S. Exemption (Territorial) Tax System
Robert J. Peroni, Exploring the Contours of a Proposed U.S. Exemption (Territorial) Tax System, 109 Tax Notes 1557 (2005) (with J. Clifton Fleming, Jr.). [Reprinted in 41 Tax Notes International 217 (2006).]
year-2004
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Article
Tax Reform Interrupted: The Chaotic State of Tax Policy in 2003
Robert J. Peroni, Tax Reform Interrupted: The Chaotic State of Tax Policy in 2003, 35 McGeorge Law Review 277 (2004). -
Article
Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax--What's ETI Repeal Got To Do With It?
Robert J. Peroni, Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax--What's ETI Repeal Got To Do With It?, 104 Tax Notes 1393 (2004) (with J. Clifton Fleming, Jr.). [Reprinted in 35 Tax Notes International 1081 (2004).] -
Book
Hemingway Oil and Gas Law and Taxation
John S. Dzienkowski, Owen L. Anderson, Robert J. Peroni, Ernest E. Smith, John S. Lowe, David E. Pierce, Hemingway Oil and Gas Law and Taxation, St. Paul: Thomson/West (4th ed. 2004)
year-2003
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Article
A Hitchhiker's Guide to Reform of the Foreign Tax Credit Limitation
Robert J. Peroni, A Hitchhiker's Guide to Reform of the Foreign Tax Credit Limitation, 56 SMU Law Review 391 (2003). -
Article
Reform and Simplification of the U.S. Foreign Tax Credit Rules
Robert J. Peroni, Reform and Simplification of the U.S. Foreign Tax Credit Rules, 101 Tax Notes 103 (2003) (with J. Clifton Fleming, Jr. & Stephen E. Shay). [Reprinted in 31 Tax Notes International 1177 (2003).] -
Article
Commentator: Response to Professor McDaniel's Article [Stephen L. Cantor International Tax Symposium]
Robert J. Peroni, Commentator: Response to Professor McDaniel's Article [Stephen L. Cantor International Tax Symposium], 35 George Washington International Law Review 297 (2003).
year-2002
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Article
The Decline in Lawyer Independence: Lawyer Equity Investments in Clients
Robert J. Peroni, The Decline in Lawyer Independence: Lawyer Equity Investments in Clients, 81 Texas Law Review 405 (2002) (with John S. Dzienkowski). -
Article
The David R. Tillinghast Lecture: "What's Source Got to Do With It?"--Source Rules and U.S. International Taxation
Robert J. Peroni, The David R. Tillinghast Lecture: "What's Source Got to Do With It?"--Source Rules and U.S. International Taxation, 56 Tax Law Review 81 (2002) (with Stephen E. Shay & J. Clifton Fleming, Jr.).
year-2001
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Article
The Proper Approach to Taxing the Income of Foreign Controlled Corporations
Robert J. Peroni, The Proper Approach to Taxing the Income of Foreign Controlled Corporations, 26 Brooklyn Journal of International Law 1579 (2001).