NCJ Number
104316
Journal
Wisconsin International Law Journal Volume: 1984 Dated: (1984) Pages: 101-130
Date Published
1984
Length
30 pages
Annotation
This article examines the role of U.S. competent authorities developed under tax treaties, with primary emphasis on the availability of adjustments which resolve incidences of double taxation.
Abstract
Recognizing that domestic measures are often insufficient for dealing with the complexities of taxing international trade, nations have formed bilateral and multilateral international treaties. Most tax treaties include administrative provisions that authorize the resolution of threats of double taxation case by case through negotiations toward agreements between designated tax officials, known as competent authorities, of the nations which are parties to the treaty. After discussing double taxation and tax treaties, this article describes the mutual agreement and exchange of information procedures, followed by a discussion of the practical implications of these mechanisms. The article argues that the role of the competent authorities under tax treaties enhances the mutual education of treaty parties and assists in the development of an international tax regime. Such a development would provide nations with a base on which to assess tax and decrease the number of disputes. It would also provide taxpayers with a degree of certainty currently lacking in international taxation. 206 footnotes.