The Resource Interpretation or override? Introducing the hybrid tax agreement

Interpretation or override? Introducing the hybrid tax agreement

Label
Interpretation or override? Introducing the hybrid tax agreement
Title
Interpretation or override? Introducing the hybrid tax agreement
Creator
Subject
Language
eng
Summary
In the effort to overcome foreign law impediments to the implementation of the Foreign Account Tax Compliance Act (FATCA), the U.S. Treasury introduced intergovernmental agreements (IGAs). IGAs are hybrid tax agreements: treaties to most of the world, in the United States they constitute an executive interpretation of the underlying tax treaty. This introduces a great deal of interpretive uncertainty where the terms of IGAs and tax treaties conflict. Prompted by recent queries in the EU regarding the legal nature of the IGAs, the author explores a concrete example of the legal principles at stake
Citation source
In: Tax notes international. - Falls Church. - Vol. 80 (2015),
Geographic coverage
North America
Language note
English
Label
Interpretation or override? Introducing the hybrid tax agreement
Instantiates
Publication
Label
Interpretation or override? Introducing the hybrid tax agreement
Publication

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