publications
Law Review and Peer-Reviewed Journal Articles
A Critique of the Private Law Approach to Tax Interpretation in Brazilian Scholarship (in Portuguese, 18:3 Revista Direito GV (2022), pp. 1-25.
Designing an Equitable Border Carbon Adjustment Mechanism, 70:1 Canadian Tax Journal/Revue fiscale canadienne (2022), pp. 1-33.
Origin and Differentiation in International Income Allocation, 44:1 Dalhousie Law Journal (2021), pp. 129-150.
An Alternative Unified Approach to Global Tax Policy: Addressing the Challenges of Underdevelopment, co-authored with Tarcísio Diniz Magalhães, 4:1 Nordic Journal on Law and Society (2021), pp. 1-31.
Inter-nation Equity Revisited, 12:1 Columbia Journal of Tax Law (2020), pp. 58-88.
Two Accounts of International Tax Justice, 33:2 Canadian Journal of Law and Jurisprudence (2020), pp. 317-339.
Institutional and Structural Legitimacy Deficits in the International Tax Regime, 12:1 World Tax Journal (2019), pp. 53-78.
Tax Competition and the Ethics of Burden Sharing, 42:1 Fordham International Law Journal (2018).
A Critique of the External Theory of Constitutional Rights: A False Dichotomy? (in Portuguese), 28:122 Revista de Direito Constitucional e International (2020), pp. 301-323.
Value-Added Tax and the Taxation of Digital Assets (in Portuguese), co-authored with Luciano Garcia Miguel, 1 Revista de Direito Tributário Contemporâneo (2016), pp. 31-68.
Taxation of Freight and the Interpretation of Conflicting and Overlapping Tax Expenditure Rules (in Portuguese), 102 Revista de Estudos Tributários (2015), pp. 9-30.
BOOKS AND BOOK CHAPTERS
Tax Expenditures and the Value-Added Tax (in Portuguese) (Rio de Janeiro: Lumen Juris, 2019).
Between Legitimacy and Justice in International Tax Policy, in Peter Harris & Dominic de Cogan, eds, Tax Justice and Tax Law: Understanding Unfairness in Tax Systems (Oxford: Hart Publishing, 2020), pp. 187-200.
Value-Added Tax and Advance Tax Rulings in the State of São Paulo (in Portuguese), co-authored with Osvaldo Santos de Carvalho, in Marcelo M Peixoto, ed, Value-Added Tax – Practical Issues: Studies in Honour of Professor Luís Fernando da Silva (São Paulo: MP Editora, 2017) 179.
Freight Taxation and Legal Issues Relating to Credit Eligibility (in Portuguese), in Eduardo P Salusse & Antonio A S P de Carvalho, eds, Tax Law: Studies in Honour of 80 Years of the Tax Court of São Paulo (São Paulo: MP Editora, 2015) 249.
Contractor Restitution in Void Public Procurement Contracts: Objective Good Faith, Consequentialism, and Legal Certainty (in Portuguese), in André R Corrêa & Mario E Pinto, Jr, eds, Contract Performance and Reason of State (São Paulo: Saraiva, 2013), pp. 219-287.
Other Publications, Media and Interviews
Tax Cooperation in an Unjust World, 2022:4 British Tax Review (2022), pp. 482-488 (book review).
Implementing a Differential Carbon Border Adjustment Mechanism: How to Design a CBAM Compliant with International Law, blog post, Kluwer International Tax Blog (6 June 2022).
Global Justice, Differentiation and the Taxation of the Digital Economy, blog post, GLOBTAXGOV (5 October 2020).
The Shift Toward a Distribution-Based Tax Framework in a Post-Pandemic World, symposium article, Afronomics Law (21 July 2020).
Tax Expenditures and Complexity in a VAT System, blog post, Council on Economic Policies (7 January 2020).
Taxer l’économie numérique : mission impossible? Une entrevue avec Ivan Ozai, interview, Canadian International Council (6 December 2019).
Taxing Digital Businesses Requires Global Approach, op-ed, Policy Options (9 September 2019).
How a U.S. Supreme Court Ruling Could Modernize Canada’s Tax System, op-ed, The Conversation (8 July 2018), featured in the National Post, the Calgary Herald, among others.
Managing Indirect Taxes in the Digital Age: Interview with Ivan Ozawa Ozai, interview, EY (12 July 2016).
Legal Norm as a Linguistic Phenomenon: A Pragmatic-Semiotic Perspective (in Portuguese), online article, 22 Revista Jus Navigandi (2017).
Value-Added Tax and Advance Tax Rulings (in Portuguese), op-ed, Carta Forense (5 July 2016).
São Paulo to Impose Tax on Software Downloads (in Portuguese), interview, Estadão (8 October 2015), featured in Folhapress, Diário de Pernambuco, among others.
Voluntary Disclosure Doesn’t Waive Penalty (in Portuguese), interview, Valor Econômico (14 September 2015).
In Debate: The Relationship between the State and Private Initiative (in Portuguese), interview, Correio Braziliense (23 September 2011).