Current Articles, Papers, Etc. Available in Adobe PDF Format

• Testimony of Michael J. McIntyre and Robert S. McIntyre On the Proposed Income Tax Treaties with France, Malta, and New Zealand Before the U.S. Senate Committee on Foreign Relations, November 10, 2009.
• How to End the Charade of Information Exchange, 56 Tax Notes Int'l 255-268 (October 26, 2009).
• Identifying tax losses entitled to full loss offsets in a business profits tax under the Domar-Musgrave risk model, 24 Australian Tax Forum 77-88 (2009).
• The Deduction of Interest Payments in an Ideal Tax on Realized Business Profits, Chapter 11, pp. 385-406, in John G. Head and Richard Krever, Eds., Tax Reform in the 21st Century: A Volume in Memory of Richard Musgrave, Kluwer Law International (2009).
• Testimony of Michael J. McIntyre and Robert S. McIntyre On Banking Secrecy Practices and Wealthy American Taxpayers Before the U.S. House Committee on Ways and Means Subcommittee on Select Revenue Measures, March 31, 2009.
• Michigan's New Apportioned Value Added Tax, 51 State Tax Notes 673-687 (March 2, 2009) (with Richard D. Pomp).
• A Program for International Tax Reform, 122 Tax Notes 1021 (Feb. 23, 2009) (bigger print version ).
• In Memorium: OLIVER OLDMAN, 122 Harvard Law Review 1285-1306 (2009), Essays by William P. Alford, Richard M. Bird, Michael J. McIntyre, Minoru Nakazato and J. Mark Ramseyer, Richard Pomp, and Eric M. Zolt. For my essay only (1291-95), please click here.
• Oliver Oldman, a Remembrance, 50 State Tax Notes 706, 52 Tax Notes Int'l 841, 121 Tax Notes 1320 (Dec. 15, 2008).
• A Policy Analysis of Michigan's Mislabeled Gross Receipts Tax, 53 Wayne Law Review 1275-1319 (2007) (with Richard D. Pomp) (published Sept. 2008).
  • Abstract
• Sydney Conference Honors Memory of Richard Musgrave
  51 Tax Notes Int'l 175-78 (July 14, 2008).
• Coming Soon---A UN Code of Conduct on tax evasion?, 4/1 Tax Justice Focus (2008).
• Point & Counterpoint: Tax-Free Overtime Pay, Creating Tax Unfairness, Vol. 27, Number 1 ABA Tax Section News Quarterly 10-12 (Fall 2007).
• Raise Michigan's top income tax rate, Detroit Free Press, Friday, May 4, 2007.
• Comments on the OECD Proposal for Secret and Mandatory Arbitration of International Tax Disputes, 7 Florida Tax Review 622-647 (2006).
  • Abstract.
  • As submitted to OECD, March 24, 2006.
  • Letter referencing this article from Senators Byron L. Dorgan, Russ Feingold, and Carl Levin to Treasury Secretary John W. Snow, May 16, 2006.
• The Case for Free Trade, Vol. 24, Number 2 ABA Tax Section News Quarterly 11-12 (Winter 2005).
• The Use of Combined Reporting by Nation States, in chapter 8, Arnold, Sasseville, & Zolt, eds. The Taxation of Business Profits Under Tax Treaties (2003). Summary. Revised and reprinted in 35 Tax Notes Int'l 917-948 (Sept. 6, 2004).
• Determining the Residence of Members of a Corporate Group, 51/4 Canadian Tax Journal 1567-73 (2003). Summary.
• Thoughts on the Future of the State Corporate Income Tax, 25 State Tax Notes 931-947 (Sept, 23, 2002). Summary.
• Pensées on Integration: Where's the Reform?
  27 State Tax Notes 971-973 (March 17, 2003).
• How the United States Should Respond to the ETI Dilemma, 26 Tax Notes Int'l 865-872 (May 20, 2002), reprinted in 95 Tax Notes 1251-1255 (May 20, 2002). Summary. Ways and Means testimony (Paean to free trade), April 10, 2002.
• Ways & Means Retreat testimony (Why "territorial" source-based tax is bad idea), April 25, 2002.
• Options for Greater International Coordination and Cooperation in the Tax Treaty Area, 56/6 Bulletin for International Fiscal Documentation 250-253 (June 2002).
• U.S. Taxation of Foreign Corporations in the Digital Age, 55 (9/10) Bulletin for International Fiscal Documentation 498 (2001). Summary.
• U.S. Income Taxation of Electronic Sales: A Virtual Office as Fixed Place of Business (adapted from 55 (9/10) Bulletin for International Fiscal Documentation 498 (2001).
• Hunt-Wesson and the Continuing Problem of Tax Arbitrage, 6 The State and Local Tax Lawyer 57-87 (2001). Summary.
• Michael J. McIntyre, Paull Mines, and Richard D. Pomp, Designing a Combined Reporting Regime for a State Corporate Income Tax: A Case Study of Louisiana, 61/4 Louisiana Law Review 699 (2001), reprinted 21/10 State Tax Notes 741-769 (Sept. 3, 2001). Summary.
• Robert S. McIntyre and Michael J. McIntyre, Fixing the 'Marriage Penalty' Problem, 33 Valparaiso University Law Review 907-946 (1999).
• Constitutional Limitations on State Power to Combat Tax Arbitrage: An Evaluation of the Hunt-Wesson Case, 18/1 State Tax Notes 51-64 (January 3, 2000).
• High Court's Ruling in Hunt-Wesson Lacks Principled Basis, 18/9 State Tax Notes 698-699 (February 28, 2000).
• Taxing Electronic Commerce Fairly and Efficiently, 52 Tax Law Review 625-654 (1997).
• Defense of OECD Harmful Tax Competition Report, 81 Tax Notes 1437-38 (1998).
• Defense of Subpart F Against Financial Services Industry, No. 1 and No. 2 (1997)
• Vietnam Report (1996).
• The Design of Tax Rules for the North American Free Trade Alliance, 49 Tax Law Review 769 (1994).

Opinion Pieces

• "What the U.S. really doesn't need is further tax cuts for the rich," The Ann Arbor News, Nov. 15, 2005, A6.
• APA Report and Territorial Taxation (Letter to Editor), 20 Tax Notes Int'l 1775 (Apr. 17, 2000), 87 Tax Notes 445 (Apr. 17, 2000).

Work in Progress

• "Limitations on Congressional Power under the Commerce Clause to Constrain State Taxing Power."
• Transfer Pricing (book, forthcoming 2006).

Other Reseach Projects

• International Tax Primer, 2d edition, Kluwer Law International, 2002 (with Brian J. Arnold).

Kluwer Law International Customer Service Department 101 Philip Drive Norwell, MA 02061 Toll free: 866-269-9527 Phone: 781-871-6600 Customer Service fax: 781-681-9045 For link to the Kluwer website, click here. Note. U.S. marketing is done by Aspen Publishers.

• The International Income Tax Rules of the United States, 2 Vol., 2d edition, Lexis-Nexis/Matthew Bender. OUT of PRINT
• McIntyre Ways & Means testimony (repeal of export subsidy), April 10, 2002.
• McIntyre Ways & Means Retreat testimony (why "territorial" source-based tax is a very bad idea), April 25, 2002.

For resume, in Adobe Acrobat, click here.