Add to ORKGIn a recent paper posted on SSRN, Profs. David Rosenbloom and Fadi Shaheen argue that the Base Erosion Anti-Abuse Tax (BEAT) (IRC section 59A), as enacted in 2017, is a potential violation of Articles 23 and 24 of US tax treaties. In addition, they argue that the BEAT does not override those treaties and therefore the treaties can be relied upon to overcome the effects of the BEAT. In our opinion, this conclusion is wrong, for two reasons. First, we believe that the BEAT is not a treaty violation. Second, we believe that even if the BEAT were found to violate treaties, it is a treaty override
This note discusses the reservations added in the Senate Committee on Foreign Relations to the US-Ch...
To combat abusive tax shelters, the Department of the Treasury promulgated a general anti-abuse regu...
In this article, the author discusses treaty abuse in the Post-BEPS world and focuses on the practic...
In a recent article in Tax Notes International, H. David Rosenbloom and Fadi Shaheen argue that the ...
In a recent paper posted on SSRN, Profs. David Rosenbloom and Fadi Shaheen argue that the Base Erosi...
The Tax Cuts and Jobs Act (TCJA) includes several provisions that may be viewed as potential violati...
The ability of some countries to unilaterally change, or override;\u27 their tax treaties through d...
During the past 25 years, Congress has with increasing frequency enacted legislation that is intende...
The book explores the problem of abuse prevention in tax treaty law from the 1977 OECD Model Tax Con...
This article addresses the treaty compatibility aspect of proposals for reforming the U.S. internati...
In recent years, there has been a dramatic increase in the attention given to abusive tax schemes th...
US Tax treaties have been regarded as self-executing since the first treaty (with France) was ratifi...
The Tax Cuts and Jobs Act of 2017 imposes a new tax regime known as the base erosion and anti-abuse...
In this paper, I provide an overview of the interaction between U.S. domestic law and tax treaties. ...
textabstractThis paper elaborates on the provision on tax abuse in the EU’s Anti Tax Avoidance Direc...
This note discusses the reservations added in the Senate Committee on Foreign Relations to the US-Ch...
To combat abusive tax shelters, the Department of the Treasury promulgated a general anti-abuse regu...
In this article, the author discusses treaty abuse in the Post-BEPS world and focuses on the practic...
In a recent article in Tax Notes International, H. David Rosenbloom and Fadi Shaheen argue that the ...
In a recent paper posted on SSRN, Profs. David Rosenbloom and Fadi Shaheen argue that the Base Erosi...
The Tax Cuts and Jobs Act (TCJA) includes several provisions that may be viewed as potential violati...
The ability of some countries to unilaterally change, or override;\u27 their tax treaties through d...
During the past 25 years, Congress has with increasing frequency enacted legislation that is intende...
The book explores the problem of abuse prevention in tax treaty law from the 1977 OECD Model Tax Con...
This article addresses the treaty compatibility aspect of proposals for reforming the U.S. internati...
In recent years, there has been a dramatic increase in the attention given to abusive tax schemes th...
US Tax treaties have been regarded as self-executing since the first treaty (with France) was ratifi...
The Tax Cuts and Jobs Act of 2017 imposes a new tax regime known as the base erosion and anti-abuse...
In this paper, I provide an overview of the interaction between U.S. domestic law and tax treaties. ...
textabstractThis paper elaborates on the provision on tax abuse in the EU’s Anti Tax Avoidance Direc...
This note discusses the reservations added in the Senate Committee on Foreign Relations to the US-Ch...
To combat abusive tax shelters, the Department of the Treasury promulgated a general anti-abuse regu...
In this article, the author discusses treaty abuse in the Post-BEPS world and focuses on the practic...