Defending Worldwide Taxation With A Shareholder-Based Definition Of Corporate Residence, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
BYU Law Review

Two Cheers for the Foreign Tax Credit, Even in the BEPS Era, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Faculty Scholarship

R&D Tax Incentives--Growth Panacea or Budget Trojan Horse?, Stephen E. Shay, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Designing a 21st Century Corporate Tax – An Advance U.S. Minimum Tax on Foreign Income and Other Measures to Protect the Base, Stephen E. Shay, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Some Cautions Regarding Tax Simplification, J. Clifton Fleming Jr.
Faculty Scholarship

A Hitchhiker’s Guide to Outbound International Tax Reform, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Formulary Appointment in the U.S. International Income Tax System: Putting Lipstick on a Pig?, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Faculty Scholarship

Reform and Simplification of the U.S. Foreign Tax Credit Rules, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Faculty Scholarship

Worldwide vs. Territorial Taxation: Response to Shields, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Can Tax Expenditure Analysis Be Divorced from a Normative Tax Base?: A Critique of the 'New Paradigm' and its Denouement, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Reinvigorating Tax Expenditure Analysis and its International Dimension, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Worldwide Taxation vs. Territorial Taxation: Framing the Debate, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Replacing the Federal Income Tax with a Postpaid Consumption Tax: Preliminary Thoughts Regarding a Government Matching Program for Wealthy Investors and a New Tax Policy Lens, J. Clifton Fleming Jr.
Faculty Scholarship

Framing the Debate Over Worldwide Versus Territorial Taxation, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Exploring the Contours of a Proposed U.S. Exemption (Territorial) Tax System, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax - What's ETI Repeal Got to Do with It?, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship

American Offshore Business Tax Planning: Can Australian Lawyers Get a Piece of the Action?, J. Clifton Fleming Jr.
Faculty Scholarship

The United States Should Tax U.S. Corporations on Their Worldwide Income, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Faculty Scholarship

Deferral: Consider Ending It Instead of Expanding It, J. Clifton Fleming Jr.
Faculty Scholarship

Electronic Commerce and the State and Federal Tax Bases, J. Clifton Fleming Jr.
BYU Law Review

Getting Serious About Curtailing Deferral of US Tax on Foreign Source Income, Robert J. Peroni, J. Clifton Fleming Jr., Stephen E. Shay
Faculty Scholarship

U.S. Taxation of Profits from Internet software Sales - An Electronic Commerce Case Study, J. Clifton Fleming Jr.
Faculty Scholarship

The Deceptively Disparate Treatment of Business and Investment Interest Expense Under a Cash-Flow Consumption Tax and a Schanz-Haig-Simons Income Tax, J. Clifton Fleming Jr.
Faculty Scholarship

Ending the IRS as We Know It: Thoughts from Outside the Beltway, J. Clifton Fleming Jr.
Faculty Scholarship

Scoping Out the Uncertain Simplification (Complication?) Effects of VATs, BATs, and Consumed Income Taxes, J. Clifton Fleming Jr.
Faculty Scholarship

A Second Look at the Zero Basis Hoax, J. Clifton Fleming Jr.
Faculty Scholarship

Renewing Progressive Taxation by Relying More on Spending, J. Clifton Fleming Jr.
Faculty Scholarship

Altering U.S. Treaty Policy to Permit the Negotiating of Zero Withholding on Portfolio Dividends: An Invitation to Research, J. Clifton Fleming Jr.
Faculty Scholarship

The Unfinished Business of Section 1244: Removing the Remaining Traps, J. Clifton Fleming Jr.
Faculty Scholarship

Has the 1976 Tax Reform Act Injected a Gain-Seeking Requirement Into Section 166?, J. Clifton Fleming Jr.
Faculty Scholarship