The second reason for the necessity to rethink international tax allocation is a change in the
basic policy assumptions both from a legal and a public finance background. Traditional …

This chapter examines the details of international income tax as an aid to understanding and
drafting the parts of the income tax law dealing with international issues. Given the large …

* I wish to thank the following people: Michael Graetz-for his supervision, comments, and
general sense of direction; Reuven Avi-Yonah, Ann Alstott, Daniel Markovits, and Richard …

Economists tend to view trade between two countries as advantageous to both sides. 1
Accordingly, in a world of open borders and no taxes, global investments would flow to the …

Worldwide income taxation in the country of residence is a legal dogma of international
taxation. We question this dogma from the perspective of relations between developed and …

This Second Edition provides an updated and succinct, yet highly informative overview of
the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading …

No rules of international law exist to limit the extent of ally country's tax jurisdiction.'Similarly,
no rules exist to require a country to grant relief from international double taxation. Whether …

My object in this paper is to explore a design for a system of international income taxation
that is at once very different from, and very similar to, the one we have today. The similarity is …

Differing provisions in bilateral tax treaties lead to undesired consequences. Tax
administrations expend considerable energy combating tax structures devised by taxpayers …

The current international tax regime is a flawed miracle. 1 It is a miracle because taxes are
the last topic on which one would expect sovereign nations to reach a consensus …