Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 1 of 1
Full-Text Articles in Law
How Reform-Friendly Are U.S. Tax Treaties?, Fadi Shaheen
How Reform-Friendly Are U.S. Tax Treaties?, Fadi Shaheen
Brooklyn Journal of International Law
This article addresses the treaty compatibility aspect of proposals for reforming the U.S. international tax system. Finding that a reform proposal is treaty compatible obviates the need for renegotiating or overriding existing U.S. treaties to implement the proposal if enacted. After establishing that a U.S. move to an exemption system would be treaty compatible despite the literal reading of Article 23 of the U.S. Model income tax treaty as requiring a credit system, the article argues that any system that is or can be expressed as an outright fixed or floating combination of exemption and credit is treaty compatible regardless …