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Full-Text Articles in Tax Law
The Limits Of Administrative Guidance In The Interpretation Of Tax Treaties, Michael Kirsch
The Limits Of Administrative Guidance In The Interpretation Of Tax Treaties, Michael Kirsch
Michael Kirsch
This Article addresses the increasingly important role of administrative guidance in interpreting the United States' international treaty obligations. The relationship between administrative guidance and treaties raises important issues at the intersection of international law, constitutional law, and administrative law. These issues are explored in the context of the United States' extensive tax treaty network. Tax treaties play an important role in a global economy, attempting to reconcile the complex and ever-changing internal tax laws of different countries. The Treasury Department is considering the increased use of administrative guidance to interpret the meaning and application of tax treaties, particularly in response …
Go Abroad, Young Man, Go Abroad: The Economic Recovery Tax Act Of 1981'S Changes In The Treatment Of Foreign Earned Income, Sheldon J. Fleming
Go Abroad, Young Man, Go Abroad: The Economic Recovery Tax Act Of 1981'S Changes In The Treatment Of Foreign Earned Income, Sheldon J. Fleming
Pepperdine Law Review
The Economic Recovery Tax Act of 1981 made major revisions in the taxation of foreign earned income. The former tax provisions of sections 911 and 913failed in their purpose of equitably compensating individuals for the increased costs of working abroad, and have been replaced with a new section 911. The new law encourages Americans to go abroad by according them the most liberal tax benefits in over fifty years.
Tax Advice For The Second Obama Administration, Michael J. Graetz
Tax Advice For The Second Obama Administration, Michael J. Graetz
Faculty Scholarship
Delivered January 18, 2013 as the keynote address at a conference cosponsored by Pepperdine Law School and Tax Analysts.