Omri Y. Marian

University of California, Irvine School of Law

Professor of Law

401 E. Peltason Dr.

Ste. 1000

Irvine, CA 92697-1000

United States

  • University of California, Irvine School of Law

SCHOLARLY PAPERS

23

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13,385

SSRN CITATIONS
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Top 41,946

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9

CROSSREF CITATIONS

8

Scholarly Papers (23)

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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 5,687 (1,576)
Citation 2

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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 1,414 (16,066)
Citation 3

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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 901 (31,351)
Citation 5

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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 578 (56,725)

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

5.

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: 14 Feb 2020
Elliott Ash and Omri Y. Marian
ETH Zürich and University of California, Irvine School of Law
Downloads 438 (79,779)

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

6.

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 401 (88,442)

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inversions, competitiveness

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 392 (90,775)

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

8.

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 367 (97,942)

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comparative taxation, comparative law

9.

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 337 (107,779)

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

10.

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 302 (121,396)

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

11.

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 292 (125,766)

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comparative tax law

12.

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 264 (139,721)

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

13.

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 254 (145,166)

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International Tax, Corporate Tax, Tax Jurisdiction, Tax Residence

14.

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 251 (146,959)

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15.

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 250 (147,479)

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

16.

New Technologies and the Evolution of Tax Compliance

Virginia Tax Review, Vol. 39, No.3, Spring 2020, UC Irvine School of Law Research Paper No. 2020-42
Number of pages: 71 Posted: 18 May 2020
James Alm, Joyce Beebe, Michael S. Kirsch, Omri Y. Marian and Jay A. Soled
Tulane University, Rice University - Baker Institute for Public Policy, Notre Dame Law School, University of California, Irvine School of Law and Rutgers University
Downloads 239 (154,094)

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17.

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 198 (184,115)

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

18.

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: 17 Jul 2020
Omri Y. Marian
University of California, Irvine School of Law
Downloads 181 (199,496)

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

19.

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 166 (214,847)
Citation 1

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

20.

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 160 (221,665)

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

21.

Taxing Data

UC Irvine School of Law Research Paper No. 2021-17, Brigham Young University Law Review, 2021 (forthcoming)
Number of pages: 61 Posted: 26 Feb 2021 Last Revised: 09 Apr 2021
Omri Y. Marian
University of California, Irvine School of Law
Downloads 136 (253,162)

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22.

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, Boston College 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, Deceased, 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 104 (307,299)

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

23.

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 73 (381,612)

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TCJA, BEAT, International Tax, Tax Refrom

Other Papers (1)

Total Downloads: 75
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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 75

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