International Law Commons^™

The Proposed Domestic Reverse Hybrid Entity Regulations: Can The Treasury Department Override Treaties?, Anthony C. Infanti

Articles

This article first describes the proposed regulations issued under section 894 addressing the ability of domestic reverse hybrid entities to claim treaty benefits with respect to payments made to their interest holders (the proposed DRH regulations). After describing the proposed DRH regulations, the article next explores the potential that these regulations have to override existing U.S. treaty obligations. After concluding that the proposed DRH regulations are inconsistent with at least one existing treaty, the article concludes by questioning the power of the Treasury Department to promulgate regulations (such as the proposed DRH regulations) that override treaties.

Note: This is a …

The United States And The International Criminal Court: A Recommendation For The Bush Administration, Michael P. Scharf

ILSA Journal of International & Comparative Law

In the waning days of his presidency, William J. Clinton authorized the United States signature of the Rome Treaty establishing an International Criminal Court (ICC), making the United States the 138th country to sign the treaty by the December 30th deadline.

Judicial Activism In The Icj Charter Interpretation, Lara M. Pair

ILSA Journal of International & Comparative Law

Judicial activism has a wide variety of definitions, while its true content remains unclear.