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The Limits Of Administrative Guidance In The Interpretation Of Tax Treaties, Michael Kirsch Nov 2013

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 …


The Key To Unlocking The Power Of Small Scale Renewable Energy: Local Land Use Regulation, Patricia Salkin May 2013

The Key To Unlocking The Power Of Small Scale Renewable Energy: Local Land Use Regulation, Patricia Salkin

Patricia E. Salkin

Myriad federal and state programs have been promoted to incentivize the research and development of renewable energy as a means of achieving sustainability and producing more affordable alternative energy systems, and these programs could potentially have a profound impact on the way that electricity is produced and consumed in the United States. Small-scale renewable energy generation from sources such as solar and wind, that can be used at the consumer level as a source of power for homes and small businesses, is an important part of this paradigm shift. However, regardless of the fiscal incentives offered to clean-tech companies to …


Hearing On Regulating The Regulators - Reducing Burdens On Small Business, Rena I. Steinzor Mar 2013

Hearing On Regulating The Regulators - Reducing Burdens On Small Business, Rena I. Steinzor

Rena I. Steinzor

No abstract provided.