Robert J. Peroni

University of Texas at Austin - School of Law

Parker C. Fielder Regents Professor in Tax Law

727 East Dean Keeton Street

Austin, TX 78705

United States

SCHOLARLY PAPERS

24

DOWNLOADS
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Top 7,518

in Total Papers Downloads

4,821

CITATIONS
Rank 16,345

SSRN RANKINGS

Top 16,345

in Total Papers Citations

21

Scholarly Papers (24)

The Decline in Lawyer Independence: Lawyer Equity Investments in Clients

GWU Law School, Public Law Research Paper No. 56; and U of Texas Law, Public Law Research Paper No. 45
Number of pages: 146 Posted: 14 Jan 2003
John S. Dzienkowski and Robert J. Peroni
University of Texas at Austin - Kay Bailey Hutchison Center for Energy, Law & Business and University of Texas at Austin - School of Law
Downloads 597 (34,631)
Citation 2

Abstract:

lawyer equity investments, venture capital, silicon valley law firms, Model Rule 1.8(a)

The Decline in Lawyer Independence: Lawyer Equity Investments in Clients

Texas Law Review, Vol. 81, No. 411, 2002-2003, The University of Texas School of Law, Public Law and Legal Theory Research Paper Series Number 490
Number of pages: 147 Posted: 16 Jun 2013
John S. Dzienkowski and Robert J. Peroni
University of Texas at Austin - Kay Bailey Hutchison Center for Energy, Law & Business and University of Texas at Austin - School of Law
Downloads 37 (371,520)
Citation 2

Abstract:

2.

Fairness in International Taxation: The Ability-to-Pay Case for Taxing Worldwide Income

Florida Tax Review, Vol. 5, No. 4, 2001
Number of pages: 29 Posted: 17 Oct 2007
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 356 (53,670)
Citation 3

Abstract:

International Taxation, Taxation, International, Fairness, Equity

3.

Some Perspectives from the United States on the Worldwide Taxation vs. Territorial Taxation Debate

Journal of the Australasian Tax Teachers Association, Vol. 3, No. 35, 2008
Number of pages: 52 Posted: 26 Jul 2009
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 351 (52,192)

Abstract:

International taxation, income taxation, taxation federal

4.

Reinvigorating Tax Expenditure Analysis and its International Dimension

27 Virginia Tax Review 437 (2008)
Number of pages: 126 Posted: 11 Apr 2008 Last Revised: 09 Jun 2015
J. Clifton Fleming Jr. and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 283 (78,961)

Abstract:

Taxation, Transnational Taxation, International Taxation

5.

Worse than Exemption

Emory Law Journal, Vol. 59, No. 1, October 2009
Number of pages: 72 Posted: 17 Jan 2010 Last Revised: 09 Jun 2015
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 263 (69,219)
Citation 1

Abstract:

Income Taxation, International Taxation, Transnational Taxation, Tax Policy

6.

Getting Serious About Curtailing Deferral of U.S. Tax on Foreign Source Income

Southern Methodist University Law Review, Vol. 52, No. 2, 1999
Number of pages: 37 Posted: 22 Feb 2008
Robert J. Peroni, J. Clifton Fleming Jr. and Stephen E. Shay
University of Texas at Austin - School of Law, Brigham Young University - J. Reuben Clark Law School and Harvard Law School
Downloads 247 (84,479)
Citation 5

Abstract:

Taxation, Transnational Taxation, International Taxation

7.

Designing a U.S. Exemption System for Foreign Income When the Treasury is Empty

Florida Tax Review, Vol. 13, No. 8, 2012
Number of pages: 70 Posted: 10 Jan 2013
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 180 (108,644)

Abstract:

Income Taxation, International Taxation, Transnational Taxation, International Law, International Business

8.

Can Tax Expenditure Analysis Be Divorced from a Normative Tax Base?: A Critique of the 'New Paradigm' and its Denouement

Virginia Tax Review, Vol. 30, p. 135, 2010
Number of pages: 46 Posted: 11 Sep 2010
J. Clifton Fleming Jr. and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 176 (121,120)

Abstract:

Income Taxation,Taxation,Tax Expenditure Analysis,Tax Policy, Public Policy, Public Finance

9.

Formulary Apportionment in the U.S. International Income Tax System: Putting Lipstick on a Pig?

Michigan Journal of International Law, Vol. 36, No. 1, 2014
Number of pages: 57 Posted: 21 Jan 2015
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 141 (118,875)

Abstract:

income taxation, international taxation, international tax reform, tax reform

10.

Exploring the Contours of a Proposed U.S. Exemption (Territorial) Tax System

Tax Notes International, p. 217, January 16, 2006, Tax Notes, Vol. 109, No. 12, December 19, 2005
Number of pages: 25 Posted: 16 Dec 2005 Last Revised: 09 Jun 2015
J. Clifton Fleming Jr. and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 122 (176,890)
Citation 4

Abstract:

international taxation, taxation, international, income taxation

11.

A Hitchhiker's Guide to Outbound International Tax Reform

Chapman Law Review, Vol. 18, p. 133, 2014
Number of pages: 24 Posted: 08 Nov 2014
J. Clifton Fleming Jr. and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 101 (194,137)

Abstract:

Income Tax, International Taxation, Tax Reform, Outbound Taxation, International Law

12.

Reform and Simplification of the U.S. Foreign Tax Credit Rules

Tax Notes, Vol. 101, No. 1, October 6, 2003
Number of pages: 35 Posted: 03 Oct 2003 Last Revised: 09 Jun 2015
Robert J. Peroni, J. Clifton Fleming Jr. and Stephen E. Shay
University of Texas at Austin - School of Law, Brigham Young University - J. Reuben Clark Law School and Harvard Law School
Downloads 83 (207,137)
Citation 2

Abstract:

13.

Getting Serious About Cross-Border Earnings Stripping: Establishing an Analytical Framework

North Carolina Law Review, Vol. 93, p. 673, 2015, BYU Law Research Paper No. 15-11
Number of pages: 70 Posted: 01 Apr 2015
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 66 (159,477)

Abstract:

Income Taxation, International Taxation, Earnings Stripping, Inversions, Corporate Inversions, Interest Expense, Thin Capitalization

14.

Territoriality in Search of Principles and Revenue: Camp and Enzi

141 Tax Notes 173, 72 Tax Notes International 155
Number of pages: 36 Posted: 16 Oct 2013
Stephen E. Shay, J. Clifton Fleming Jr. and Robert J. Peroni
Harvard Law School, Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 64 (201,714)

Abstract:

Income Taxation, International Taxation, Territorial Taxation, Tax Reform

15.

Multidisciplinary Practice and the American Legal Profession: A Market Approach to Regulating the Delivery of Legal Services in the Twenty-First Century

Fordham Law Review, Vol. 83 2000-2001, U of Texas Law, Public Law Research Paper No. 463
Number of pages: 129 Posted: 15 Jun 2013
John S. Dzienkowski and Robert J. Peroni
University of Texas at Austin - Kay Bailey Hutchison Center for Energy, Law & Business and University of Texas at Austin - School of Law
Downloads 63 (184,644)
Citation 1

Abstract:

16.

Conflicts of Interest in Lawyer Referral Arrangements with Nonlawyer Professional

Georgetown Journal of Legal Ethics, Vol. 21, No. 197, 2008, The University of Texas School of Law, Public Law and Legal Theory Research Paper Series Number 459
Number of pages: 41 Posted: 13 Jun 2013
John S. Dzienkowski and Robert J. Peroni
University of Texas at Austin - Kay Bailey Hutchison Center for Energy, Law & Business and University of Texas at Austin - School of Law
Downloads 57 (260,146)

Abstract:

17.

Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax - What's ETI Repeal Got to Do with It‘

Tax Notes, Vol. 104, No. 13, September 20, 2004
Number of pages: 28 Posted: 18 Sep 2004 Last Revised: 09 Jun 2015
J. Clifton Fleming Jr. and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 51 (260,146)
Citation 3

Abstract:

18.

Designing a 21st Century Corporate Tax -- An Advance U.S. Minimum Tax on Foreign Income and Other Measures to Protect the Base

Florida Tax Review, Vol. 17, 2015, BYU Law Research Paper No. 15-21
Number of pages: 61 Posted: 28 Aug 2015 Last Revised: 24 Nov 2015
Stephen E. Shay, J. Clifton Fleming Jr. and Robert J. Peroni
Harvard Law School, Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 17 (113,989)

Abstract:

Corporate Tax, Minimum Tax, International Tax, Income Tax, Controlled Foreign Corporations, Base Erosion

19.

Getting from Here to There: The Transition Tax Issue

154 Tax Notes, March 27, 2017, at 69, U of Texas Law, Public Law Research Paper No. 671
Number of pages: 13 Posted: 05 Apr 2017 Last Revised: 16 May 2017
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 0 (229,653)

Abstract:

20.

Defending Worldwide Taxation with a Shareholder-Based Definition of Corporate Residence

Brigham Young University Law Review, Vol. 2016, No. 6, 2017, U of Texas Law, Public Law Research Paper No. 663
Number of pages: 34 Posted: 05 Mar 2017
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 0 (243,127)

Abstract:

Income Taxation, International Taxation, International Income Taxation, Residence, Corporate Residence

21.

Two Cheers for the Foreign Tax Credit, Even in the BEPS Era

91 Tulane L. Rev. 1 (2016)
Number of pages: 55 Posted: 17 Nov 2016 Last Revised: 25 Apr 2017
J. Clifton Fleming Jr., Robert J. Peroni and Stephen E. Shay
Brigham Young University - J. Reuben Clark Law School, University of Texas at Austin - School of Law and Harvard Law School
Downloads 0 (170,790)

Abstract:

22.

R&D Tax Incentives: Growth Panacea or Budget Trojan Horse?

Tax Law Review, Vol. 69, 2016
Number of pages: 40 Posted: 17 Oct 2016
Stephen E. Shay, J. Clifton Fleming Jr. and Robert J. Peroni
Harvard Law School, Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 0 (227,976)

Abstract:

23.

Treasury's Unfinished Work on Corporate Expatriations

150 Tax Notes, Policy Perspective
Number of pages: 10 Posted: 23 Feb 2016
Stephen E. Shay, J. Clifton Fleming Jr. and Robert J. Peroni
Harvard Law School, Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 0 (123,400)

Abstract:

24.

Reform in the Use of Phase-Outs and Floors in the Individual Income Tax System

Tax Notes, Vol. 91, No. 9, May 28, 2001 (Special Supplement)
Posted: 24 May 2001
Robert J. Peroni
University of Texas at Austin - School of Law

Abstract: