Assistant Professor of Law
International taxation, comparative taxation, taxation of financial instruments
Omri Marian teaches and writes in the areas of international taxation and taxation of financial instruments. Professor Marian’s work has been cited by Congress and is frequently featured in financial media outlets. In his current research, Prof. Marian explores the administrative practices of tax haven jurisdictions and the responses of industrialized jurisdictions to such practices.
Before joining UC Irvine School of Law, he was an assistant Professor of Law at the University of Florida. He also practiced as a tax associate at the New York office of Sullivan & Cromwell LLP.
U.S. International Taxation, Tax Treaties, International Tax Planning, Taxation of Financial Instruments
- “The State Administration of International Tax Avoidance,” UC Irvine School of Law Research Paper No. 2015-95 (2015), Harv. Bus. L. Rev. (Forthcoming, 2016). Prompted line of inquiry at European Parliament Taxe Committee hearing here >
- “Unilateral Responses to Tax Treaty Abuse: A Functional Approach,” 41 Brook. J. Int’l L. (Forthcoming, 2016)
- “Inversions and Competitiveness: Reflections in the Wake of Pfizer--Allergan,” 41 Int’L Tax J. 39 (2015), with Reuven S. Avi-Yonah.
- “Home-Country Effects of Corporate Inversions,” 90 Wash. L. Rev 1 (2015). Cited by The Joint Committee on Taxation here >
- “A Conceptual Framework for the Regulation of Cryptocurrencies,” 82 U. Chi. L. Rev. Dialogue 53 (2015)
- “Reconciling Tax Law and Securities Regulation,” 48 Mich. J. L. Reform 1 (2014)
- “Jurisdiction to Tax Corporations,” 54 B.C. L. Rev. 1613 (2013)
- “Are Cryptocurrencies Super Tax Havens?” 112 Mich. L. Rev. First Impressions 38 (2013). Cited by the Congressional Research Service here >
- May 23, 2016
Panelist, “How Tax Transparency Could Lead to Better Global Tax Rules,” Tax Coop 2016 conference, World Bank, Washington, D.C.
- Apr. 29, 2016
Presenter, The State Administration of International Tax Avoidance, Workshop on Corruption and the Role of Tax Havens, City University London
- Mar. 11, 2016
Presenter, Private Investment Funds and International Tax Avoidance, Brigham Young University Law Review Symposium, Provo, UT
- Mar. 1, 2016
Presenter, The State Administration of International Tax Avoidance, Georgetown University Tax Law and Public Finance Workshop, Washington, D.C.
- Feb. 11, 2016
Presenter, The State Administration of International Tax Avoidance, UCLA School of Law Colloquium on Tax Policy and Public Finance, Los Angeles
- Jan. 25, 2016
Presenter, The State Administration of International Tax Avoidance, Pepperdine Law School Tax Policy Series, Malibu, CA
- Nov. 19, 2015
Presenter, The State Administration of International Tax Avoidance, The National Tax Association 108th Annual Conference on Taxation, Boston
- Oct. 23, 2015
Presenter, Tax Treaty Terminations (and other Unilateral Responses to Treaty Abuse), Brooklyn Law School Symposium
- Malta Today: Prof. Marian quoted re: Malta’s foreign dividend refund scheme
- Ars Technica: Prof. Marian quoted re: whether U.S. would pass a “tax holiday” on foreign earnings
- Bloomberg Law: Prof. Marian discusses European Commission decision to fine Apple Corp. a record €13 billion ($14.5 billion) plus interest after Ireland slashed company’s tax bill (audio)
- Luxemburger Wort: Prof. Marian quoted in Luxembourg news article on lessons of LuxLeaks (PDF in German)
- Luxemburger Wort: Prof. Marian interviewed by Luxembourg news re: new tax rules resulting from LuxLeaks (PDF in German)
- CNBC: Analysis by Prof. Marian referenced in commentary re: impact of tax inversions
- Deutsche Welle Broadcasting: Prof. Marian quoted by German media re: fallout from Panama Papers leak and where U.S. fits in this picture
- The Wall Street Journal: Prof. Marian quoted re: the most recent tax inversion transaction by Johnson Controls-Tyco
- Wall Street Journal: Quoted in Johnson Controls-Tyco Deal Adds to U.S. Tax Exodus
- La Presse: Interviewed for Que faisait Quebecor World en Suisse sous Péladeau?
- Tax Notes International: Letter to the Editor: What ‘Assault’ on American Companies?
- Ars Technica: Quoted in If Apple didn’t hold $181B overseas, it would owe $59B in US Taxes
- Ars Techinca: Quoted in Kickstarter, unlike Etsy, says it won’t use “esoteric” tax strategies
- Ars Technica: Interviewed for Despite transparency claims, Etsy ups secrecy and shifts profits overseas
- New York Times: Home Country Effects of Corporate Inversions cited in How Obama’s Tax Plan May Not Work as Intended