Assistant Professor of Law
International taxation, comparative taxation, taxation of financial instruments
Omri Marian is an internationally recognized expert in international taxation and comparative taxation. Before joining UC Irvine School of Law, he was an assistant Professor of Law at the University of Florida where he taught in the graduate tax program. He also practiced as a tax associate in the New York office of Sullivan & Cromwell LLP. Professor Marian’s work has been cited by Congress and is frequently featured in financial media outlets.
U.S. International Taxation, Tax Treaties, International Tax Planning, Taxation of Financial Instruments, Current Issues in Tax Law and Policy
- Omri Y. Marian, United States National Report on Corporate Tax Residence and Mobility, in Proceedings of 2017 Congress of European Association of Tax Law Professors (forthcoming, 2017).
- Omri Y. Marian, The State Administration of International Tax Avoidance, 7 HARV. BUS. L. REV. __ (forthcoming, 2017).
Reviewed at: Andrew Hayashi, Putting a Face To International Tax Avoidance (noting the article’s “valuable contribution in drawing attention to the powers of individual actors” in international tax avoidance).
- Omri Y. Marian, The Other Eighty Percent: Private Investment Funds, International Tax Avoidance, and Tax-Exempt Investors, 2016 BYU L. REV. 1516 (2016); Invited symposium article.
Reviewed by Ari Glogower on Taxprof Blog (concluding the article “is a significant step” towards “a broader perspective on tax planning by investment funds”).
- Omri Y. Marian, Is Something Rotten in the Grand Duchy of Luxembourg?, 84 TAX NOTES INT’L 281 (Oct. 17, 2016). Trade journal article (cover feature).
- Omri Y. Marian, Unilateral Responses to Tax Treaty Abuse: A Functional Approach, 41 BROOK. J. INT’L L. 1155 (2016); an invited contribution for a symposium “Reconsidering the Tax Treaty.”
- Omri Y. Marian, Is Something Rotten in the Grand Duchy of Luxembourg?, 84 Tax Notes Int’l 281 (Oct. 17, 2016).
- Omri Y. Marian & Reuven S. Avi-Yonah, Inversions and Competitiveness: Reflections in the Wake of Pfizer--Allergan, 41 Int’L Tax J. 39 (2015).
- Omri Y. Marian, Home-Country Effects of Corporate Inversions, 90 Wash. L. Rev 1 (2015). Cited by The Joint Committee on Taxation in, Description of Revenue Provisions Contained in the President's Fiscal Year 2015 Budget Proposal (Dec. 17, 2014)>
- Omri Y. Marian, A Conceptual Framework for the Regulation of Cryptocurrencies, 82 U. Chi. L. Rev. Dialogue 53 (2015); an invited essay for an online symposium “Grassroots Innovation and Regulatory Adaptation”.
- Omri Y. Marian, Reconciling Tax Law and Securities Regulation, 48 Mich. J. L. Reform 1 (2014).
- Omri Y. Marian, Jurisdiction to Tax Corporations, 54 B.C. L. Rev. 1613 (2013).
- Omri Y. Marian, Are Cryptocurrencies Super Tax Havens?, 112 Mich. L. Rev. First Impressions 38 (2013). Cited by the Congressional Research Service here >
- June 2017
United States National Reporter on Corporate Tax Residence and Mobility, the 2017 Congress of European Association of Tax Law Professors, Lodz, Poland
- April 2017
The Making of International Tax Law: Empirical Evidence from Natural Language Processing, The Northern California Tax Professor Roundtable, Hastings Law School, San Francisco, CA
- November 2016
The State Administration of International Tax Avoidance, University of Virginia Invitational Tax Conference, Charlottesville, VA
- August 8, 2016
Private Investment Funds and International Tax Avoidance, Discussant, Tax Policy Discussion Group, Annual Meeting of the South Eastern Association of Law School, Amelia Island, FL.
- July 2016
The State Administration of International Tax Avoidance, 3rd Annual Roundtable on Taxation and Tax Policy, Netanya Academic College School of Law, Netanya, Israel
- June 2016
Private Investment Funds and International Tax Avoidance, 11th Annual Junior Tax Scholars Workshop, University of California, Irvine School of Law, Irvine, CA
- June 2016
Allocation of Income from a Lawyer’s Perspective, University of Zurich Invitational Seminar: Tax Justice in a Global World, Zurich, Switzerland
- May 2016
Tax Investigations and their Impact on the Global Tax System, Winning the Tax Wars conference, The World Bank, Washington, DC.
- 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
- Luxemburger Wort: EU schließt Schlupflöcher mit Drittstaaten. (In German)
- Tax Notes International: AG Recommends Lighter Sentences for LuxLeaks Defendants on Appeal.
- Ars Technica: Prof. Marian quoted: Strange bond arrangement Apple is using has been around for decades
- The New York Times: Prof. Marian quoted re: whether Bitcoin users were aware virtual currencies are taxable
- 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