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Tax Law

Introduction

Background

International Tax Law Research involves looking at a number of different sources of law.  Tax treaties, foreign law, and domestic tax law can all have an impact.  Below are some resources to help with finding international tax law, including secondary sources, multilateral treaties, bilateral treaties, foreign law, as well as some additional resources  This guide offers a brief overview of a very complex subject.  For more detailed information, see the following research guides: Georgetown Law Library's International and Foreign Tax Law Research Guide and New York University Law Library's Foreign & International Tax Research Guide.

Secondary Sources

Introductory Secondary Sources

Introductory resources, such as student study aids, can provide background information regarding a broad area of the law.  They are good for starting research in a new area of the law to get a broad overview of the topic.

International Tax Law in a Nutshell KF6419.Z9 D64 2018 [also available electronically via West Study Aids]

Advanced Introduction to International Tax Law K4460 .A95 2015 provides a concise yet wide-ranging overview of the key issues surrounding taxation and international law from a world authority on international tax.

Treatises

Treatises are in-depth resources that provide extensive explanation, analysis, and interpretation of an area of the law.  They are usually written by scholars in the field, and provide many citations to primary law.

Rhoades & Langer US International Taxation and Tax Treaties KF6306 .R48 [available electronically via Lexis Advance] This treatise provides in-depth analysis of all relevant Internal Revenue Code provisions and Treasury Regulations and Rulings, annotated text of every U.S. income tax treaty, as well as key features such as summary status sheets to identify all treaties and agreements currently in force, concise general rules, and timesaving examples and tables.

International Taxation: U.S. Taxation of Foreign Persons and Foreign Income KF6441 .I83 5th International Taxation is a comprehensive four volume treatise providing in-depth discussion and insightful analysis of the United States tax regime as applied to international transactions. Covering both inbound and outbound transactions, the author reduces the most complicated issues to clear, understandable and practical domestic and foreign-based tax strategies.

International Tax Treatises (WG&L) Database [available electronically via Westlaw Edge]

Kuntz & Peroni: U.S. International Taxation (WG&L) [available electronically via Westlaw Edge] a treatise on U.S. taxation of U.S. taxpayers with foreign activities or income, and foreign taxpayers with U.S. activities.

Levey: U.S. Taxation of Foreign Controlled Businesses (WG&L) [available electronically via Westlaw Edge] helps U.S. practitioners understand the tax implications of conducting international business. The treatise covers inbound transactions that address the unique issues of non-U.S. businesses operating in the United States, as well as outbound transactions that discuss the tax implications of doing business in Canada, Mexico, Japan, the United Kingdom, France, Germany, and the Netherlands.

Lowell & Martin: U.S. International Taxation: Practice & Procedure (WG&L) [available electronically via Westlaw Edge] provides step-by-step advice on handling IRS international examinations, from information document requests to the preparation of protests and alternative dispute submissions. Guidance is also provided on how to structure and support a transfer pricing plan.

Hammer, Lowell, Burge, & Levey: International Transfer Pricing: OECD Guidelines (WG&L) [available electronically via Westlaw Edge] contains a thorough discussion of transfer pricing under the guidelines of the Organization of Economic Cooperation and Development (OECD) covering global trading, Internet transactions, and the use of so-called virtual companies. Written for tax practitioners involved in the design, structure, and analysis of international transactions between multinational entities doing business in the developed countries, this treatise provides detailed, step-by-step guidance for planning, documentation, and compliance under the OECD guidelines, including penalties and local administrative procedures.

Langer on Practical International Tax Planning [available electronically via PLI Plus] This resource provides users with information regarding legal, tax, business, financial, social, political, technological, geographical, and regional factors to consider when developing and implementing customized planning strategies for clients.

Primary Law

Tax Treaties

There are 3 main types of tax treaties: multilateral tax treaties, model tax treaties, and bilateral tax treaties.

There are only a few multilateral tax treaties, the following is a list of selected multilateral treaties (it is not exhaustive) - Vienna Convention on the Law of Treaties; Convention on Mutual Administrative Assistance in Tax Matters; Protocol Amending the Convention on Mutual Assistance in Tax Matters; Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI).

Model Tax Treaties serve as a starting point for negotiations.  They are not binding.  There are 3 main model tax treaties - OECD Model Tax Convention; US Model Income Tax Convention; UN Model Tax Convention.

In the US, bilateral treaties are usually discussed as bilateral treaties to which the US is a party and bilateral treaties to which the US is NOT a party.  Bilateral treaties involving the US can be found on the IRS' website.  It is more difficult to find English translations of bilateral treaties not involving the US.  These may be available on foreign legislature's websites or on dedicated international tax law databases.

Foreign Tax Legislation

For finding foreign tax legislation, Foreign Law Guide and NYU Law GlobaLex are good starting points.  These resources provide users with an overview of foreign countries' system of government, as well as links to various resources for accessing primary law.