March's Tax Reflections With Reuven Avi-Yonah

Reuven S. Avi-Yonah (Michigan; Google Scholar):

Why the United States Needs a GAAR, 182 Tax Notes Fed. 1809 (Mar. 4, 2024):

Avi-Yonah advocates for Congress to adopt a general antiabuse rule to combat loopholes formed by the voluminous tax code.

Should Digital Services Taxes Be Creditable?, 182 Tax Notes Fed. 2031 (Mar. 11, 2024):

Avi-Yonah argues that because digital services taxes are used to offset the taxation impediment that “digital giants” cannot be taxed under permanent establishment rules, they should qualify as an in-lieu-of tax and therefore be creditable.

Answering the Right Question in Rawat, 182 Tax Notes Fed. 2207 (Mar. 18, 2024):

Avi-Yonah redirects discussion of Rawat to international tax issues, arguing that the problem in the case stems from a lack of coordination between sections 741 and 751 and section 865.