Omri Y. Marian

University of California, Irvine School of Law

Assistant Professor

401 E. Peltason Dr.

Ste. 1000

Irvine, CA 92697-1000

United States

  • University of California, Irvine School of Law

SCHOLARLY PAPERS

21

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Top 3,131

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11,815

SSRN CITATIONS
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Top 44,689

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3

CROSSREF CITATIONS

8

Scholarly Papers (21)

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1.

Are Cryptocurrencies 'Super' Tax Havens?

112 Michigan Law Review First Impressions 38 (2013)
Number of pages: 11 Posted: 05 Aug 2013 Last Revised: 05 Jul 2015
Omri Y. Marian
University of California, Irvine School of Law
Downloads 5,440 (1,296)
Citation 1

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Bitcoin, Tax Evasion, Tax Havens, FATCA, Virtual Currencies, Offshore Bank Accounts

2.

A Conceptual Framework for the Regulation of Cryptocurrencies

82 University of Chicago Law Review Dialogue 53 (2015)
Number of pages: 16 Posted: 15 Oct 2014 Last Revised: 23 Oct 2015
Omri Y. Marian
University of California, Irvine School of Law
Downloads 1,248 (15,642)
Citation 2

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Cryptocurrencies, Bitcoin, Tax Evasion, Regulation, Criminal Behavior, Privacy, Decentralization, Economics of Crime, Public Ledger, Financial Intermediaries

3.

The State Administration of International Tax Avoidance

1 Harvard Business Law Review, Vol. 7, 2017, UC Irvine School of Law Research Paper No. 2015-95
Number of pages: 67 Posted: 04 Nov 2015 Last Revised: 20 Oct 2017
Omri Y. Marian
University of California, Irvine School of Law
Downloads 825 (28,737)
Citation 3

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International Tax, Tax Arbitrage, Tax Avoidance, Lux Leaks, LuxLeaks

4.

Home-Country Effects of Corporate Inversions

90 Washington Law Review 1 (2015)
Number of pages: 73 Posted: 28 Aug 2014 Last Revised: 20 Jan 2016
Omri Y. Marian
University of California, Irvine School of Law
Downloads 575 (46,753)

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Inversions, Corporate Tax, International Tax, Tax Reform, Comparative Tax

5.

Inversions and Competitiveness: Reflections in the Wake of Pfizer/Allergan

U of Michigan Law & Econ Research Paper No. 15-021, U of Michigan Public Law Research Paper No. 488
Number of pages: 15 Posted: 16 Dec 2015 Last Revised: 11 Feb 2016
Reuven S. Avi-Yonah and Omri Y. Marian
University of Michigan Law School and University of California, Irvine School of Law
Downloads 385 (76,636)

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inversions, competitiveness

6.

The Discursive Failure in Comparative Tax Law

American Journal of Comparative Law, Vol. 58, No. 2, 2010
Number of pages: 77 Posted: 14 May 2009 Last Revised: 26 Feb 2013
Omri Y. Marian
University of California, Irvine School of Law
Downloads 356 (83,944)

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comparative taxation, comparative law

7.

Is Something Rotten in the Grand Duchy of Luxembourg?

Tax Notes International, Vol. 84, 2016
Number of pages: 13 Posted: 29 Oct 2016
Omri Y. Marian
University of California, Irvine School of Law
Downloads 353 (84,741)

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LuxLeaks, Tax Administration, Tax Avoidance, TAXE, State Aid, International Taxation

8.

Jurisdiction to Tax Corporations

54 Boston College Law Review 1613 (2013)
Number of pages: 54 Posted: 09 Apr 2013 Last Revised: 28 Sep 2013
Omri Y. Marian
University of California, Irvine School of Law
Downloads 326 (92,687)

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International Taxation, Corporate Taxation, Tax Jurisdiction, Comparative Taxation, Tax Reform

9.

The Other Eighty Percent: Private Investment Funds, International Tax Avoidance, and Tax-Exempt Investors

Brigham Young University Law Review, Vol. 2016, 2016, UC Irvine School of Law Research Paper No. 2017-10
Number of pages: 49 Posted: 27 Dec 2016 Last Revised: 14 Feb 2017
Omri Y. Marian
University of California, Irvine School of Law
Downloads 283 (108,120)

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Private Equity, Venture Capital, Hedge Funds, International Taxation, Tax Avoidance, Luxleaks, BEPS, Country by Country Reporting

10.

Comparative Tax Law in Theory and Practice

Number of pages: 3 Posted: 09 Dec 2009
Guy Inbar, Linneu Albuquerque Mello, Omri Y. Marian and Reuven S. Avi-Yonah
affiliation not provided to SSRN, affiliation not provided to SSRN, University of California, Irvine School of Law and University of Michigan Law School
Downloads 276 (111,104)

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comparative tax law

11.

Meaningless Comparisons: Corporate Tax Reform Discourse in the United States

32 Virginia Tax Review 133 (2012)
Number of pages: 72 Posted: 09 Apr 2012 Last Revised: 02 Jan 2013
Omri Y. Marian
University of California, Irvine School of Law
Downloads 253 (121,649)

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Comparative Taxation, Comparative Law, Legal Reform, International Taxation, Tax Reform Discourse

12.

Meaningful Corporate Tax Residence

Tax Notes, Vol. 140, No. 5, 2013
Number of pages: 10 Posted: 01 Aug 2013
Omri Y. Marian
University of California, Irvine School of Law
Downloads 233 (132,194)

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International Tax, Corporate Tax, Tax Jurisdiction, Tax Residence

13.

Is All Corporate Tax Planning Good for Shareholders?

52 UC Davis Law Review 2018 (Forthcoming), UC Irvine School of Law Research Paper No. 2018-20
Number of pages: 69 Posted: 19 Mar 2018 Last Revised: 21 Mar 2018
Omri Y. Marian
University of California, Irvine School of Law
Downloads 221 (139,210)

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Corporate Taxation, Tax Avoidance, Corporate Governance, Agency Costs, Tax Exempt Investors, Gross Up, Fiduciary Duties, Economic Analysis of Law

14.

Unilateral Responses to Tax Treaty Abuse: A Functional Approach

Brooklyn Journal of International Law, Vol. 41, 2016 (Forthcoming), UC Irvine School of Law Research Paper No. 2017-09
Number of pages: 23 Posted: 10 Mar 2016 Last Revised: 14 Feb 2017
Omri Y. Marian
University of California, Irvine School of Law
Downloads 179 (169,214)

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International Taxation, Corporate Taxation, Tax Jurisdiction, Comparative Taxation, Tax Treaties, Tax Avoidance, BEPS

15.

The Function of Corporate Tax-Residence in Territorial Systems

18 Chapman Law Review 157 (2014)
Number of pages: 28 Posted: 16 Jul 2014 Last Revised: 30 Sep 2014
Omri Y. Marian
University of California, Irvine School of Law
Downloads 169 (178,056)

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International Tax Reform; Territorial Taxation; Worldwide Taxation; Corporate Tax; Tax History; Comparative Taxation; Corporate Tax-Residence

16.

Reconciling Tax Law and Securities Regulation

48 University of Michigan Journal of Law Reform 1 (2014)
Number of pages: 58 Posted: 04 Apr 2014 Last Revised: 03 Dec 2014
Omri Y. Marian
University of California, Irvine School of Law
Downloads 161 (185,468)

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Tax Disclosure; Securities Regulation; Mandatory Disclosure; Efficient Capital Markets Hypothesis

17.

The Making of International Tax Law: Empirical Evidence from Natural Language Processing

UC Irvine School of Law Research Paper No. 2019-02
Number of pages: 47 Posted: 12 Jan 2019
Elliott Ash and Omri Y. Marian
ETH Zurich and University of California, Irvine School of Law
Downloads 159 (187,524)

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Intergovernmental Organizations, OECD, International Tax, International Law Tax Treaties, Harmonization, Natural Language Processing

18.

Taxation of Structured Debt in a Low-Rate Environment

135 Tax Notes 323 (2012)
Number of pages: 14 Posted: 18 Apr 2012
Omri Y. Marian and Andrew D. Moin
University of California, Irvine School of Law and affiliation not provided to SSRN
Downloads 154 (192,664)

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Taxation of Financial Instruments, Taxation of Structured Debt, Original Issue Discount

19.

Blockchain Havens and the Need for Their Internationally-Coordinated Regulation

North Carolina Journal of Law and Technology, Vol. 20, 2019, Forthcoming, UC Irvine School of Law Research Paper No. 2019-14
Number of pages: 32 Posted: 21 Mar 2019
Omri Y. Marian
University of California, Irvine School of Law
Downloads 140 (208,230)

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20.

A Critique of BEAT Critiques

Columbia Journal of Tax Law Tax Matters, Vol. 10, No. 1, 2018
Number of pages: 7 Posted: 31 Dec 2018
Omri Y. Marian
University of California, Irvine School of Law
Downloads 46 (405,071)

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TCJA, BEAT, International Tax, Tax Refrom

21.

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
Leandra Lederman, Susan C. Morse, Stephen E. Shay, Clint Wallace, Reuven S. Avi-Yonah, Lily L. Batchelder, Jeremy Bearer-Friend, Joshua D. Blank, Leslie Book, Bryan Camp, Noel B. Cunningham, Victor Fleischer, J. Clifton Fleming, Keith Fogg, David Gamage, Ari D. Glogower, Mitchell Kane, Ariel Jurow Kleiman, Edward D. Kleinbard, Rebecca M. Kysar, Zachary D. Liscow, Ruth Mason, Omri Y. Marian, Robert J. Peroni, Darien Shanske, Daniel Shaviro, John P. Steines, Bret Wells and Eric M. Zolt
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 33 (456,836)

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

Other Papers (1)

Total Downloads: 73
Actions:
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1.

What 'Assault' on American Companies?

81 Tax Notes International 265 (Jan. 18, 2016)
Number of pages: 3 Posted: 21 Jan 2016
Omri Y. Marian
University of California, Irvine School of Law
Downloads 73

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