Ruth Mason

U.S. Tax Treaty Policy and the European Court of Justice

PUBLISHER
Tax Law Review
DATE
2005 Autumn
 

Abstract

This Article considers the effects of EC law on U.S. tax treaty policy. The discussion is framed by the controversy over the legality of tax treaty limitation on benefits clauses (LOBs) in the wake of recent ECJ decisions, and it argues that U.S. tax treaty policy is on a collision course with the tax jurisprudence of the ECJ.

Citation

Ruth Mason, U.S. Tax Treaty Policy and the European Court of Justice, 59 Tax Law Review 65-132 (2005).
 

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