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Full-Text Articles in Taxation-Transnational
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
Robert A. Green
This background note consists of two parts. Part one provides an overview of the extent to which tax matters are currently covered in non-tax treaties. This discussion focuses on the general agreement on tariffs and trade (GATT)/World Trade Organization (WTO) agreement and the North American free trade agreement (NAFTA) (which cover direct tax measures only to a limited extent) and the European Community (EC) treaty (which covers direct tax measures more broadly). Part two outlines the issues raised when tax matters are covered in non-tax treaties.
The Troubled Rule Of Nondiscrimination In Taxing Foreign Direct Investment, Robert A. Green
The Troubled Rule Of Nondiscrimination In Taxing Foreign Direct Investment, Robert A. Green
Robert A. Green
[Abstract needed]
Antilegalistic Approaches To Resolving Disputes Between Governments: A Comparison Of The International Tax And Trade Regimes, Robert A. Green
Antilegalistic Approaches To Resolving Disputes Between Governments: A Comparison Of The International Tax And Trade Regimes, Robert A. Green
Robert A. Green
No abstract provided.
Pari Passu To Gunboats: Nml V. Argentina, Vassilis Paliouras
Pari Passu To Gunboats: Nml V. Argentina, Vassilis Paliouras
Bocconi Legal Papers
This article provides a detailed overview of the latest litigation saga before the courts of the state of New York between NML Capital, a distressed debt hedge fund owned by Elliott Management Corporation, and Argentina. The two of them arguably constitute the most aggressive players in the area of sovereign debt, and it comes with no surprise that much of the relative law has been framed by disputes to which, either one or both of them, were parties. At the heart of the present dispute was the interpretation of the pari passu (originally meaning “on equal step/footing”) clause that was …