Add to ORKGIn a recent article in Tax Notes International, H. David Rosenbloom and Fadi Shaheen argue that the base erosion and antiabuse tax (IRC section 59A, as enacted in 2017) is a potential violation of articles 23 and 24 of U.S. tax treaties. They say the BEAT does not override those treaties, so those agreements can be relied on to overcome the effects of the BEAT. In our opinion, that conclusion is wrong for two reasons: The BEAT is not a treaty violation, and even if were, it is a treaty override
In this paper, I provide an overview of the interaction between U.S. domestic law and tax treaties. ...
Abstract: The effects of bilateral tax treaties on FDI activity have been unexplored, despite signi...
In this article, the authors provide a summary of the anti-avoidance rules in the United States that...
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...
This article addresses the treaty compatibility aspect of proposals for reforming the U.S. internati...
US Tax treaties have been regarded as self-executing since the first treaty (with France) was ratifi...
This note discusses the reservations added in the Senate Committee on Foreign Relations to the US-Ch...
The Tax Cuts and Jobs Act of 2017 imposes a new tax regime known as the base erosion and anti-abuse...
The book explores the problem of abuse prevention in tax treaty law from the 1977 OECD Model Tax Con...
This Article describes how Zenith Electronics Corp. v. United States ( Zenith ) made the treatment o...
The OECD's public discussion draft 'BEPS Action 6: Preventing the Granting of Treaty Benefits in Ina...
In this paper, I provide an overview of the interaction between U.S. domestic law and tax treaties. ...
Abstract: The effects of bilateral tax treaties on FDI activity have been unexplored, despite signi...
In this article, the authors provide a summary of the anti-avoidance rules in the United States that...
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...
This article addresses the treaty compatibility aspect of proposals for reforming the U.S. internati...
US Tax treaties have been regarded as self-executing since the first treaty (with France) was ratifi...
This note discusses the reservations added in the Senate Committee on Foreign Relations to the US-Ch...
The Tax Cuts and Jobs Act of 2017 imposes a new tax regime known as the base erosion and anti-abuse...
The book explores the problem of abuse prevention in tax treaty law from the 1977 OECD Model Tax Con...
This Article describes how Zenith Electronics Corp. v. United States ( Zenith ) made the treatment o...
The OECD's public discussion draft 'BEPS Action 6: Preventing the Granting of Treaty Benefits in Ina...
In this paper, I provide an overview of the interaction between U.S. domestic law and tax treaties. ...
Abstract: The effects of bilateral tax treaties on FDI activity have been unexplored, despite signi...
In this article, the authors provide a summary of the anti-avoidance rules in the United States that...