Law Commons^™

The United States Policy Of Stringent Anti-Treaty-Shopping Provisions: A Comparative Analysis, Simone M. Haug

Vanderbilt Journal of Transnational Law

Tax avoidance through international treaty shopping has become a subject of intense controversy in the international community. By shrewdly structuring businesses, corporations are currently able to take advantage of tax exemptions contained in tax treaties, though the countries that have joined the treaties never intended for them to benefit from such provisions. Many nations, including the United States, view this practice as tax treaty abuse. In response to such abuses, many countries are now incorporating strict anti-treaty-shopping provisions in their bilateral tax treaties.

Ms. Haug begins the Article by describing the practice of treaty shopping and, specifically, the various methods …

Income Tax Treaty Shopping: An Overview Of Prevention Techniques, Kenneth A. Grady

Northwestern Journal of International Law & Business

The Internal Revenue Service in recent years has been particularly concerned about third-country residents use of bilateral income tax treaties to avoid paying tax on United States source income. Although third-country residents have benefitted from United States bilateral income tax treaties for more than twenty years, the loss of tax revenue from such unintended use was not considered a major problem. The recent proliferation of tax treaties between the United States and tax havens which resulted in an increased loss of tax revenues, however, has caused the Internal Revenue Service (IRS) to change its evaluation of the treaty shopping problem. …

Recent Decisions, John E. Drake, Heidi A. Rohrbach, John R. Hellinger, Elizabeth G. Browning

Vanderbilt Journal of Transnational Law

CHOICE OF LAW--WRONGFUL DEATH--GOVERNMENTAL-INTEREST ANALYSIS DETERMINES LAW APPLICABLE TO MEASURE OF DAMAGES IN CLAIMS ARISING FROM FOREIGN Air CRASH

John Edison Drake

===============

EUROPEAN COMMUNITIES--FREE MOVEMENT OF WORKERS--COURT OF JUSTICE SETS GUIDELINES FOR USE BY MEMBER STATES OF THE PUBLIC POLICY EXCEPTION IN ARTICLE 48

Heidi A. Rohrbach

================

TAX TREATIES--UNITED STATES MAY USE THE INTERNAL REVENUE CODE SUMMONING AUTHORITY TO OBTAIN DOMESTIC INFORMATION SOLELY TO AID A FOREIGN DOMESTIC TAX INVESTIGATION PURSUANT TO A TAX TREATY

John R. Hellinger

==============

TREATY INTERPRETATION--WARSAW CONVENTION-- PASSENGERS UNDERGOING SEARCH PREREQUISITE TO BOARDING ARE ENGAGED IN OPERATIONS OF EMBARKING

Elizabeth Graeme Browning

Recent Important Decisions

Michigan Law Review

A collection of recent important court decisions.