About Me

I work at the intersection of law, taxation, and policy design, where cross-border systems meet real economic activity. My professional life has been shaped by one central idea: legal rules matter most not in theory, but in how they operate in practice, under pressure, and across jurisdictions.

My path into this space was not linear, but cumulative. Training in business law, securities, arbitration, and regulatory systems gave me an early understanding of how commercial structures are built. Years in cross-border practice then showed me how those structures are tested by tax treaties, withholding rules, permanent establishment thresholds, anti-avoidance standards, and administrative discretion. What began as transaction work gradually evolved into a deeper inquiry: why legal systems produce the outcomes they do, and how those outcomes can be made more coherent.

My academic work in international taxation refined this inquiry. At Osgoode Hall, my focus was not on isolated doctrines but on how domestic rules sit inside global frameworks. GAAR, the OECD Principal Purpose Test, CFC regimes, treaty interpretation, beneficial ownership, FAPI, and BEPS reforms are not merely technical tools. They are policy instruments that reveal how states balance revenue protection, economic competitiveness, and legal certainty. Understanding the mechanics of these rules is only the first step. Understanding their design logic, their limits, and their interaction is what gives them meaning.

This systems perspective now defines how I think and write. I am interested in pressure points — the places where treaty allocation meets domestic compliance, where administrative discretion meets judicial review, where anti-avoidance standards meet commercial reality, and where global coordination meets national law. My work on GAAR, treaty shopping, CFC rules, FAPI, service income characterization, and tax litigation procedure reflects this orientation. Each topic is approached not as a standalone issue, but as part of a larger legal architecture.

At the same time, my work remains grounded in practice. Advising on cross-border structures, permanent establishment exposure, withholding obligations, beneficial ownership, and regulatory alignment across jurisdictions has reinforced a simple lesson: complexity must be made usable. A rule that cannot be applied predictably is not a solution. Clarity, structure, and coherence are not academic preferences; they are professional necessities.

This belief also shapes my teaching. Through my educational venture, AGP e-Class, I train students and young lawyers to think in frameworks rather than fragments. Legal education, in my view, should not produce note collectors, but structured thinkers. A rule must be understood, its purpose located, its interaction mapped, and its limits recognized. When that happens, complexity becomes navigable. That same method underlies how I write for academic and professional audiences.

My work sits naturally between scholarship, professional practice, and policy. I am drawn to questions that matter for system design: how anti-avoidance standards should be calibrated, how treaty protections should be accessed in practice, how domestic law should respond to international coordination, and how judicial review can remain a meaningful check in tax administration. These are not purely technical issues. They shape investment behavior, administrative capacity, and trust in legal systems.

Ultimately, I see my role as helping make cross-border legal frameworks more intelligible, more coherent, and more aligned with their underlying policy objectives. Whether writing, advising, or teaching, my aim is consistent: to connect rules to purpose, doctrine to design, and complexity to clarity.