International Tax as International Law: An Analysis of the International Tax Regime

International Tax as International Law: An Analysis of the International Tax Regime

by Reuven S. Avi-Yonah
     
 

This book examines the coherent international tax regime that is embodied both in the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty-based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the… See more details below

Overview

This book examines the coherent international tax regime that is embodied both in the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty-based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how U.S. tax law embodies the underlying norms of the regime.

About the Author:
Reuven S. Avi-Yonah is the Irwin I. Cohn Professor of Law and Director of the international Tax LLM Program at the University of Michigan Law School

Product Details

ISBN-13:
9780521618014
Publisher:
Cambridge University Press
Publication date:
09/30/2007
Series:
Cambridge Tax Law Series
Edition description:
New Edition
Pages:
224
Product dimensions:
5.98(w) x 8.98(h) x 0.47(d)

Table of Contents


Introduction: Is there an international tax regime? Is it part of international law?     1
Jurisdiction to tax     22
Sourcing income and deductions     38
Taxation of nonresidents: Investment income     64
Taxation of nonresidents: Business income     79
Transfer pricing     102
Taxation of residents: Investment income     124
Taxation of residents: Business income     150
The United States and the tax treaty network     169
Tax competition, tax arbitrage, and the future of the international tax regime     182
Bibliography     189
Index     205

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