Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 2 of 2
Full-Text Articles in Law
Reconsidering The Tax Treaty, Steven Dean, Rebecca M. Kysar
Reconsidering The Tax Treaty, Steven Dean, Rebecca M. Kysar
Faculty Scholarship
For nearly one hundred years, the international tax regime steadfastly pursued a single nemesis, double taxation. States armed themselves against this common enemy with their weapon of choice, the double tax treaty. Nearly uniform in language and approach, the treaties proliferated to more than three thousand in number,1 resulting in a secure arrangement between and among states and taxpayers.
Yet in recent years, states have had to expand the war to multiple fronts in the face of globalization, technological changes, evolving taxpayer abuses, and shifts in both domestic and international political pressures. For instance, a growing recognition that the …
Follow The Money: Essays On International Taxation – Introduction, Michael J. Graetz
Follow The Money: Essays On International Taxation – Introduction, Michael J. Graetz
Faculty Scholarship
Publicity about tax avoidance techniques of multinational corporations and wealthy individuals has moved discussion of international income taxation from the backrooms of law and accounting firms to the front pages of news organizations around the world. In the words of a top Australian tax official, international tax law has now become a topic of barbeque conversations. Public anger has, in turn, brought previously arcane issues of international taxation onto the agenda of heads of government around the world.
Despite all the attention, however, issues of international income taxation are often not well understood. This Introduction outlines a collection of essays, …