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University of Michigan Law School

2007

Treaties

Comparative and Foreign Law

Articles 1 - 2 of 2

Full-Text Articles in Law

Criminal Conspiracy Law In Japan, Chris Coulson Jan 2007

Criminal Conspiracy Law In Japan, Chris Coulson

Michigan Journal of International Law

Part II of this Note describes CATOC's group criminality requirement. Part III outlines the provisions of several versions of Japan's conspiracy bill and compares these provisions to common-law conspiracy. Part IV analyzes Japan's conspiracy law by examining both substantive and procedural laws in Japan related to criminal conspiracy, as well as criticism within Japan of the conspiracy bills.


The New United States Model Income Tax Convention, Reuven S. Avi-Yonah, Martin B. Tittle Jan 2007

The New United States Model Income Tax Convention, Reuven S. Avi-Yonah, Martin B. Tittle

Articles

On 15 November 2006, the United States Treasury released its long-awaited new Model Income Tax Convention (“New Model”), which replaced the 1996 US Model (“Old Model”). This article reviews some of the major differences between the New and Old Models, as well as some of the major differences between the New Model and the current (2005) OECD Model Tax Convention. The article also discusses some new trends in US treaty policy which are not reflected in the New Model. The article concludes by evaluating the New Model in light of the emerging trend to use tax treaties not just to …