When Tax Treaty Derivative Benefits Provisions Don’t Apply

En række amerikanske præsidentkandidater og kongresmedlemmer er i de sidste år begyndt at argumentere for, at USA burde lancere militære angreb mod...

Lenders are perfectly free to decide for themselves whether, when, how, to whom and on what terms they will extend credit to a sovereign borrower. But...

Liberalism is back on its heels, pushed there by political movements in the United States and Europe and by the critiques of legal scholars and...

The Supreme Court’s recent expansion of the major questions doctrine has rocked administrative law, throwing into doubt executive agencies’ statutory...

Income inequality is a national preoccupation, and the public’s imagination is captured by the astronomical incomes of Valley tech billionaires and...

Countries hit by unexpected crises often look to their overseas diasporas for assistance. Some countries have tapped into this generosity of their...

In an era defined by partisan rifts and government gridlock, many celebrate the rare issues that prompt bipartisan consensus. But extreme consensus...

In this article, we examine the relations between risk, the choice of foreign or local contract terms (parameters), and maturity in the sovereign debt...

In this article, we examine the relations between risk, the choice of foreign or local contract terms (parameters), and maturity in the sovereign debt...

Over the past twenty-five years, Congress has enacted several major reforms for employer-sponsored retirement plans and individual retirement accounts...

There have been a lot of intriguing developments in the Hamilton Reserve Bank vs Sri Lanka litigation lately, not least mounting questions around who...

In an era characterized by inequalities of income and influence, political polarization, and the segregation of social spaces, the income tax...

Over the past quarter century, Congress has enacted several major reforms for retirement plans and individual retirement accounts, usually with large...

Both theorists and courts commonly assume that high-dollar financial contracts between sophisticated parties are free of linguistic errors...

The bill proposes a flawed and possibly unconstitutional reparations program and needs to be reworked to give Ukraine some chance at a viable post-war...

Law students frequently find the U.S. Supreme Court’s Dormant Commerce Clause doctrine confusing. That is no surprise given the sharp disagreement...

At the inception of a new and potentially transformative type of tax enforcement, this Article reviews the goals underlying the prohibition on state...

Since Russia invaded Ukraine in 2022, the United States and its allies have searched for the best way to express their horror and dismay. At the level...