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Full-Text Articles in Law
The Status Of United States International Taxation: Another Fine Mess We've Gotten Ourselves Into, Karen V. Kole
The Status Of United States International Taxation: Another Fine Mess We've Gotten Ourselves Into, Karen V. Kole
Northwestern Journal of International Law & Business
United States international tax policy in the 1980s and beyond, where are we going and why? The federal income tax has arguably taken a consistent approach to basic international issues since its inception. To this allegedly well balanced compromise between theory and practicality, an increasingly complex maze of rules has been added without much direction. The result is chaos with little apparent benefit. Contrary to the alleged intent of these piecemeal amendments, the changes have complicated, not simplified, the area of the international tax law. In trying to make an inherently imperfect system perfect, monumental administrative burdens have been imposed …
The Termination Of The United States-Netherlands Antilles Tax Treaty: What Were The Costs Of Ending Treaty Shopping, Frith Crandall
The Termination Of The United States-Netherlands Antilles Tax Treaty: What Were The Costs Of Ending Treaty Shopping, Frith Crandall
Northwestern Journal of International Law & Business
On June 29, 1987 the United States Treasury Department terminated the United States-Netherlands Antilles Tax Treaty (the "Treaty"). The United States and the Netherlands Antilles had attempted to preserve the Treaty for eight years. However, negotiations ended because of a loggerhead over the extent to which the Netherlands Antilles would maintain any tax haven status. Termination of the Treaty was a victory for the United States since third parties to the Treaty could no longer misuse it to evade United States taxes. Furthermore, the termination significantly advanced the continuing United States policy to eliminate "treaty shopping." The purpose of this …