Writing

The Sovereign Shield 

Citing the Unseen 

An Overview of AI and its applications to Tax Professionals 

Good Intentions, Bad Tools 

The Undertaxed Profits Rule (UTPR): A Case for Repealing an Extra-Territorial Tax.

The One Big Beautiful Bill – Examination of the New Tax Proposals Affecting Foreign Multinationals Operating in the U.S. 

Agentic AI in Tax Administration: Legal and Regulatory Implications

Taxing Big Tech: A Small Country's Dilemma

The OECD Pillar Two Global Minimum Tax: Foundations, Mechanisms, and Implementation Challenges (2023)

AI Hallucinations in Tax Law: Risks and Need for Human Oversight: Developed and evaluated a Tax AI Chatbot using a Stanford-inspired rubric to benchmark its responses against standard Tax AI models, focusing on correctness, groundedness, completeness, and citation accuracy. The internal study scored legal-tax prompts using a 0–5 scale with expert reviewers to assess reliability for enterprise use. 

AI-Driven Transfer-Pricing Benchmarks: Hallucination Risk, Bias Metrics, and Audit Defensibility. 

How reliable are large-language-model-generated comparables and DEMPE narratives under audit?

2019 OECD Pillar Two (GloBE) Public Consultation Comments and Recommendations: International Tax Risk Management Cohort, Texas A&M University School of Law. Available at SSRN: https://ssrn.com/abstract=5313543 or http://dx.doi.org/10.2139/ssrn.5313543  

2019 Recommendations for Pillar One 

Official Participant in the UN Subcommittee on AI and Tax Administration.

UN Tax Committee Confronts New Challenges from AI to Health Taxes

Comments with Proposed Text for the UN Intergovernmental Committee Drafting the International Tax Cooperation Convention, Wolters Kluwer Int'l Tax L. Blog (Aug. 6, 2025), 

Comments and Inputs to the Secretariat of the Ad Hoc Committee UN Framework Convention on International Tax Cooperation, United Nations Headquarters, New York

Modernizing Payments and Cross-Border Tax Refunds: Implications of U.S. Executive Order 14247

Recommendations on Items to be Included on the 2025-2026 Priority Guidance Plan

Provided technical input to ABA, GBA and Texas A&M University on the U.S. tax reform modeling under the One Big Beautiful Bill (2025).

Tax AI Whitepaper: Advocated for Tax & Customs chatbot business case  

U.S.-Swiss Treaty: Co-authored opinion on the application of the U.S.-Swiss Income Tax Treaty.

Authored opinion and facts and circumstances memorandum as part of tax due-diligence and documenting eligibility and legal positioning for the Payroll Credit 

Contributor to OECD tax transparency initiatives and publication of a large multinational Fortune 500 global tax transparency report. 

Advise and implement legal entity restructuring and cross-border holdings with evolving OECD and BEPS frameworks. 

Presented proposals at OECD Paris consultations on Pillar One and Pillar Two (2019).

Regular contributor to the Tax Notes and Wolters Kluwer Intl. Tax Law Blog on cross-border taxation. 

US Real-Time Tax Intelligence: Led the U.S. real-time tax intelligence interface that integrates IRS APIs with the in-house Tax Team, enabling automated tax alerts and an early warning system of IRS tax activities and reducing inquiry resolution time. 

US Real-Time Tariff Analytics: Contributed to developing the U.S. tariff analytics tool using the Customs ACE Portal.  

AI Tax-Assistant Bot: Led design and deployment of a web-based chatbot that uses LLM-based architecture to provide real-time tax insights, retrieve latest law changes, and support academic research on Tax AI adoption. 

US R&D Tax Credit Automation: Led the U.S. tax credit automation proprietary tool that involved the end-to-end design and implementation of an AI-powered R&D tax credit engine that automates eligibility testing, cost mappings, and audit trails within a Fortune Global 500 multinational.  

AI-Driven Transfer Pricing Benchmarks. Applied bias metrics and audit defensibility methods in practice. 

AI-Enabled Compliance Modernization. Led AI-driven automation initiatives improving tax data governance and global efficiency.

Deployed “Tax Cubes,” an AI-driven cubes for a leading Multinational Group that analyzes the tax processes of new affiliates joining the Group and benchmarks against its internal standards with an automated first 100-day action plan to remediate the gaps. 

Global BEPS Deployment. Coordinated multinational compliance programs across jurisdictions. Directed corporate implementation and liaison with OECD and UN forums. Connected Pillar Two data requirements with corporate reporting systems. 

Greenfield Investment Structuring. Designed double tax treaty based tax-efficient entry and incentive strategy for a major manufacturing expansion.

Tariff and Transfer Pricing Valuations. Resolved customs and transfer-pricing conflicts through a unified valuation methodology.