Ruth Mason
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.
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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.
Key concepts: Tax treaty, Principle of legality, Treaty, Jurisprudence, Tax law, Political science, Law, Direct tax