Stephen E. Shay

Professor of Practice

Office:	Hauser 324
Assistant:	Maura Kelley 617/495-4642
Phone:	617/384-5311
Email:	sshay@law.harvard.edu

Faculty Directory listing

Bibliography

Shorter Works in Collection

Shay, Stephen E. & Elinore J. Richardson. "Taxation Policy" in Economic Development, Foreign Investment and the Law: Issues of Private Sector Involvement, Foreign Investment and the Rule of Law in a New Era (Robert Pritchard ed., Kluwer Law International/International Bar Association, 1996).

Shay, Stephen E. "Re-examining Chapter 3 Income Tax Withholding and the Role of the Withholding Agent" in Essays on International Taxation (H. Alpert & Kees van Raad ed., Kluwer, 1993).

Articles in a Periodical

Shay, Stephen E. "Jobs, Deficit Reduction, Revenues, and Fundamental Tax Reform," 64 Tax Notes 213 (2011).
Full text: SSRN

Shay, Stephen E., J. Clifton Fleming Jr. & Robert J. Peroni. "Worse than Exemption," 59 Emory Law Journal 79 (2009).

Shay, Stephen E. "Commentary: Ownership Neutrality and Practical Complications," 62 Tax Law Review 401 (2009).

Shay, Stephen E. "American Bar Association Tax Section, Task Force on International Tax Reform, Report of the Task Force on International Tax Reform," 59 Tax Lawyer 649 (2006).
(principal draftsman)

Shay, Stephen E., J. Clifton Fleming Jr. & Robert J. Peroni. "The David R. Tillinghurst Lecture: What's Source Got to Do With It? Source Rules and U.S. International Taxation," 56 Tax Law Review 81 (2003).

Shay, Stephen E., J. Clifton Fleming Jr. & Robert J. Peroni. "Reform and Simplification of the U.S. Foreign Tax Credit Rules," 31 Tax Notes International 1145 (2003).

Shay, Stephen E., J. Clifton Fleming Jr. & Robert J. Peroni. "Fairness in International Taxation," 5 Florida Tax Review 299 (2001).

Shay, Stephen E., J. Clifton Fleming Jr. & Robert J. Peroni. "Deferral: Consider Ending It, Instead of Expanding It," 86 Tax Notes 837 (2000).

Shay, Stephen E., J. Clifton Fleming Jr. & Robert J. Peroni. "Taking Territorial Taxation to Task," 20 Tax Notes International 1178 (2000).

Shay, Stephen E., Susan C. Morse & Christopher J. Peters. "Qualified Intermediary Status, Act III: Rev. Proc. 2000-12's Final Qualified Intermediary Agreement and Amendments to Final Withholding Rules," 29 Tax Management International Journal 403 (2000).

Shay, Stephen E., J. Clifton Fleming Jr. & Robert J. Peroni. "An Alternative View of Deferral: Considering a Proposal to Curtail, Not Expand, Deferral," 20 Tax Notes International 547 (2000).

Shay, Stephen E., J. Clifton Fleming Jr. & Robert J. Peroni. "Getting Serious About Curtailing Deferral of U.S. Tax on Foreign Source Income," 52 Southern Methodist University Law Review 455 (1999).

Shay, Stephen E. & Susan C. Morse. "Qualified Intermediary Status: A New Withholding Role for Foreign Financial Institutions Under Final U.S. Withholding Regulations," 27 Tax Management International Journal 3 (1998).

Shay, Stephen E. & Victoria P. Summers. "Selected International Aspects of Tax Reform Proposals," 51 University of Miami Law Review 1029 (1997).

Shay, Stephen E. "Revisiting U.S. Anti-Deferral Rules," 74 Taxes 1042 (1996).

Shay, Stephen E. "IRS Makes Flip Transactions Taxable," 5 International Tax Review 17 (1994).

Shay, Stephen E. "Final Section 367(e) Regs. Improve on Temp Regs., But Policy Concerns Remain," 4 International Taxation 224 (1993).

Shay, Stephen E. & Rom P. Watson. "Final Dual Consolidated Loss Regs. Still Have Some High Hurdles," 4 International Taxation 52 (1993).

Shay, Stephen E. "Dispute Resolution Faces Numerous Obstacles," 3 International Tax Review 15 (1992).

Shay, Stephen E. "Section 864(e) and the Allocation of Expenses Under the Temporary Regulations," 18 Tax Management International Journal 239 (1989).

Shay, Stephen E. "The Post-TAMRA Treatment of U.S. Shareholders of PFIC's: Part I," 70 Journal of Taxation 296 (1989).

Shay, Stephen E. "The Post-TAMRA Treatment of U.S. Shareholders of PFICs: Part II," 70 Journal of Taxation 374 (1989).

Shay, Stephen E. "Section 864(e) and the Allocation and Apportionment of Interest Expense Under the Proposed Regulations," 17 Tax Management International Journal 51 (1988).

Shay, Stephen E. "The Controversial CFC Interest Netting Rule in the Proposed Interest Allocation Regulations," 17 Tax Management International Journal 25 (1988).