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

27

DOWNLOADS
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Top 7,576

in Total Papers Downloads

6,338

SSRN CITATIONS
Rank 23,826

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Top 23,826

in Total Papers Citations

7

CROSSREF CITATIONS

27

Scholarly Papers (27)

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 652 (41,862)
Citation 4

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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 61 (382,329)

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2.

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, 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 504 (59,128)

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International taxation, income taxation, taxation federal

3.

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, 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 498 (59,993)
Citation 2

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International Taxation, Taxation, International, Fairness, Equity

4.

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, 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 430 (71,876)

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Income Taxation, International Taxation, Transnational Taxation, Tax Policy

5.

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 and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 320 (100,943)

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Taxation, Transnational Taxation, International Taxation

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 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 319 (101,288)

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Taxation, Transnational Taxation, International Taxation

7.

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 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 266 (123,028)

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

8.

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, 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 261 (125,530)

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

9.

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, BYU Law Research Paper No. 17-20
Number of pages: 35 Posted: 05 Mar 2017 Last Revised: 29 Aug 2017
J. Clifton Fleming, 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 259 (126,591)
Citation 1

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

10.

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, 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 250 (131,211)

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

11.

Expanded Worldwide Versus Territorial Taxation After the TCJA

Tax Notes, Vol. 161, 2018, BYU Law Research Paper No. 19-04
Number of pages: 18 Posted: 19 Dec 2018 Last Revised: 19 Mar 2019
J. Clifton Fleming, 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 229 (142,971)

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International Income Taxation, Transnational Taxation, Tax Policy, Income Taxation

12.

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 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 220 (148,709)

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13.

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 and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 216 (151,274)

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

14.

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, 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 208 (156,732)

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15.

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, 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 199 (163,373)
Citation 1

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

16.

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, BYU Law Research Paper No. 17-21
Number of pages: 14 Posted: 05 Apr 2017 Last Revised: 29 Aug 2017
J. Clifton Fleming, 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 183 (177,136)

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17.

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 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 153 (205,671)
Citation 1

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Income Taxation, International Taxation, Territorial Taxation, Tax Reform

18.

Incorporating a Minimum Tax in a Territorial System

157 Tax Notes 73 (2017), U of Texas Law, Public Law Research Paper, BYU Law Research Paper No. 18-01
Number of pages: 15 Posted: 04 Oct 2017 Last Revised: 12 Feb 2018
J. Clifton Fleming, 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 152 (206,814)
Citation 3

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

19.

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 and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 151 (207,934)

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international taxation, taxation, international, income taxation

20.

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 145 (214,958)

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21.

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 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 142 (218,552)
Citation 1

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22.

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 and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 135 (227,546)

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

23.

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 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 131 (233,036)

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24.

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 95 (292,691)

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25.

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 and Robert J. Peroni
Brigham Young University - J. Reuben Clark Law School and University of Texas at Austin - School of Law
Downloads 88 (307,125)

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26.

Ninth Circuit Brief of Law Academics and Professors as Amici Curiae in Opposition to the Petition for Rehearing En Banc in Altera v. Commissioner

Number of pages: 34 Posted: 18 Sep 2019
Indiana University Maurer School of Law, University of Texas at Austin - School of Law, Harvard Law School, University of South Carolina School of Law, University of Michigan Law School, New York University School of Law, George Washington University Law School, University of California, Irvine School of Law, Villanova University School of Law, Texas Tech University School of Law, New York University Law School, UC-Irvine School of Law, Brigham Young University - J. Reuben Clark Law School, Tax Clinic at Legal Services Center of Harvard Law School, Indiana University Maurer School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, New York University (NYU), University of San Diego School of Law, University of Southern California Gould School of Law, Fordham University School of Law, Yale University - Law School, University of Virginia School of Law, University of California, Irvine School of Law, University of Texas at Austin - School of Law, University of California, Davis - School of Law, New York University School of Law, New York University School of Law, University of Houston Law Center and University of California, Los Angeles (UCLA) - School of Law
Downloads 71 (348,379)

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Altera, transfer pricing, arm's length, Tax Court, en banc, Section 482, stock-based compensation

27.

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

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