United States

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Jeroen Lammers & Błażej Kuźniacki, The EU Solidarity Contribution and a More…

G E Financial Investments Limited v HMRC [2021] UKFTT 210 (TC)  raised central aspects of the interpretation of double tax treaties. My previous blogs considered the corporate residence  under…

Last month my blog discussed the questions relating to corporate residence and article 4(1) of the UK-US Double Tax Treaty raised in G E Financial Investments v HMRC  [2021] UKFTT 210 (TC). This…

When is a taxpayer a resident of a contracting state for purposes of a tax treaty? The decades old definition in article 4(1) of the OECD Model that ‘“resident of a Contracting State” means any…

The present article explores some concrete application cases of Big Data in Tax Administrations (TAs). It then formulates some ideas for its possible expansion in the near future, considering both…

The relationship between treaties and domestic tax law ought to be straightforward. The pacta servanda sunt principle expressed in articles 26 and 27 of the Vienna Convention on the Law of Treaties…

Maarten de Wilde* Summary On March 31, 2021, U.S. President Biden released his ‘American Jobs Plan’, an ambitious proposal for large scale public investments in infrastructure and other priorities…

On April 5, 2021, U.S. Treasury Secretary Janet YELLEN “grabbed the attention of the occupants of corner offices worldwide with a speech to the Chicago Council on Global Affairs.  The headline was a…

The inspiration for this post is “The Made In America Tax Plan” (https://home.treasury.gov/system/files/136/MadeInAmericaTaxPlan_Report.pdf) recently released by the U.S. Department of the Treasury…