US Treaty Anti-Avoidance Rules: An Overview and Assessment

Journal
Avi-Yonah, R.S.; Halabi, O.
United States
Bulletin for International Taxation 2012 (Volume 66), No. 4/5
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In this article, the authors provide a summary of the anti-avoidance rules in the United States that relate to bilateral tax treaties. Specifically, they focus on treaty-based anti-avoidance rules and discuss whether or not a General Anti-Avoidance Rule would be appropriate in this context.