Robert J. Peroni
- The Fondren Foundation Centennial Chair for Faculty Excellence
- Professor
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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-2001
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Article
Fairness in International Taxation: The Ability-to-Pay Case for Taxing Worldwide Income
Robert J. Peroni, Fairness in International Taxation: The Ability-to-Pay Case for Taxing Worldwide Income, 5 Florida Tax Review 299 (2001) (with J. Clifton Fleming, Jr. & Stephen E. Shay). -
Article
Point: The United States Should Tax U.S. Corporations on Their Worldwide Income
Robert J. Peroni, Point: The United States Should Tax U.S. Corporations on Their Worldwide Income, ABA Section of Taxation Newsletter, Fall 2001, at 14 (with J. Clifton Fleming, Jr. & Stephen E. Shay). -
Article
Reform in the Use of Phaseouts and Floors in the Individual Income Tax System
Robert J. Peroni, Reform in the Use of Phaseouts and Floors in the Individual Income Tax System, 91 Tax Notes 1415 (2001). -
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?
Robert J. Peroni, 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 Texas Law Review 1609 (2001).
year-2000
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Article
Multidisciplinary Practice and the American Legal Profession: A Market Approach to Regulating the Delivery of Legal Services in the Twenty-First Century
John S. Dzienkowski, Multidisciplinary Practice and the American Legal Profession: A Market Approach to Regulating the Delivery of Legal Services in the Twenty-First Century, 69 Fordham Law Review 83 (2000) (with Robert J. Peroni). -
Article
An Alternative View of Deferral: Considering a Proposal to Curtail, Not Expand, Deferral
Robert J. Peroni, An Alternative View of Deferral: Considering a Proposal to Curtail, Not Expand, Deferral, 20 Tax Notes International 525 (2000) (with J. Clifton Fleming, Jr. & Stephen E. Shay). [Reprinted in 86 Tax Notes 837 (2000).]
year-1999
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Article
Shaping the Future of Law: ABA's Multidisciplinary Practice Proposals Will Stymie the Growth of MDPs
John S. Dzienkowski, Shaping the Future of Law: ABA's Multidisciplinary Practice Proposals Will Stymie the Growth of MDPs, Legal Times, Aug. 2, 1999, at 27 (with Robert J. Peroni). [Reprinted in Texas Lawyer, Aug. 9, 1999, at 38.] -
Article
ABA's Definition of Practice Flawed
John S. Dzienkowski, ABA's Definition of Practice Flawed, National Law Journal, July 26, 1999, at A27 (with Robert J. Peroni). -
Article
Getting Serious About Curtailing Deferral of U.S. Tax on Foreign Source Income
Robert J. Peroni, Getting Serious About Curtailing Deferral of U.S. Tax on Foreign Source Income, 52 SMU Law Review 455 (1999) (with J. Clifton Fleming, Jr. & Stephen E. Shay). -
Article
MDP Commission Opts for Expanded Regulation and Economic Protectionism
Robert J. Peroni, MDP Commission Opts for Expanded Regulation and Economic Protectionism, Professional Responsibility News, Summer 1999, at 5 (with John S. Dzienkowski).
year-1998
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Book
Cases and Materials on Taxation of Business Enterprises
Robert J. Peroni, Cases and Materials on Taxation of Business Enterprises (St. Paul: West, 2nd ed. 2002, with G.E. Coven & R.C. Pugh; 1st ed. 1998, with B.B. Barton, G.E. Coven, & R.C. Pugh; Teacher's Manual 2002, 1998). -
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
Robert J. Peroni, 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, 66 University of Cincinnati Law Review 1271 (1998).
year-1997
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Article
Back to the Future: A Path to Progressive Reform of the U.S. International Income Tax Rules
Robert J. Peroni, Back to the Future: A Path to Progressive Reform of the U.S. International Income Tax Rules, 51 University of Miami Law Review 975 (1997).
year-1995
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Book
Taxation of Business Enterprises
Robert J. Peroni, Taxation of Business Enterprises (Chicago, Commerce Clearing House, 1995, 1991; Teacher's Manual 1995, 1991; Supplements 1994, 1993) (with B.B. Barton, G.E. Coven, & R.C. Pugh).
year-1993
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Article
Taxing and Subsidizing Natural Resource Development
Robert J. Peroni, Taxing and Subsidizing Natural Resource Development, 6 Natural Resources Tax Review 641 (1993) (with John S. Dzienkowski). -
Article
The Energy Policy Act of 1992 and Its Impact on the Law of Natural Resources Taxation
Robert J. Peroni, The Energy Policy Act of 1992 and Its Impact on the Law of Natural Resources Taxation, 6 Natural Resources Tax Review 77 (1993) (with John S. Dzienkowski). -
Article
A Brief Critique of the Supreme Court's Opinion in the Hill Case
Robert J. Peroni, A Brief Critique of the Supreme Court's Opinion in the Hill Case, 6 Natural Resources Tax Review 151 (1993) (with John S. Dzienkowski). -
Article
Natural Resources Taxation: 1992--The Year in Review
John S. Dzienkowski, Natural Resources Taxation: 1992--The Year in Review, 6 Natural Resources Tax Review 1 (1993).
year-1992
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Article
Combining Timber Properties for Depletion Purposes: The Tax Court's Decision in RLC Industries Co. v. Commissioner
Robert J. Peroni, Combining Timber Properties for Depletion Purposes: The Tax Court's Decision in RLC Industries Co. v. Commissioner, 5 Natural Resources Tax Review 482 (1992) (with John S. Dzienkowski). -
Article
Phillips Petroleum Co. v. Commissioner: An Important Decision for the Natural Resource Operator Engaged in Multinational Operations
Robert J. Peroni, Phillips Petroleum Co. v. Commissioner: An Important Decision for the Natural Resource Operator Engaged in Multinational Operations, 4 Natural Resources Tax Review 429 (1992).
fall 2025
- Corporate Tax
- Federal Income Taxation