Fadi Shaheen

Rutgers, The State University of New Jersey - School of Law, Newark

Newark, NJ

United States

  • Rutgers, The State University of New Jersey - School of Law, Newark

SCHOLARLY PAPERS

15

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Scholarly Papers (15)

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1.

The BEAT and the Treaties

Tax Notes International, Vol. 92, No. 1, 2018
Number of pages: 12 Posted: 21 Aug 2018 Last Revised: 20 Oct 2018
H. David Rosenbloom and Fadi Shaheen
Caplin & Drysdale, Chartered and Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 516 (107,473)
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International taxation, section 59A, BEAT, Base Erosion Anti-Abuse Tax, alternative minimum tax, income tax treaties, treaty override, canons of construction, supremacy clause, nondiscrimination, foreign tax credit

2.

Tax Treaty Aspects of the McDonald's State Aid Investigation

Tax Notes International, Vol. 86, No. 4, 2017
Number of pages: 18 Posted: 23 May 2017
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 353 (166,729)

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International taxation, EU state aid, exemption, double taxation, nontaxation, conflicts of qualification

3.

The GAAP Lock-Out Effect and the Investment Behavior of Multinational Firms

67 Tax Law Review 211 (2014)
Number of pages: 38 Posted: 01 Jun 2013 Last Revised: 28 Aug 2014
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 311 (190,890)

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International taxation, foreign earnings, repatriation tax, CFC, subpart F, New View, GAAP, investment strategy, real income, book income, efficiency costs

4.

Treaty Override: The False Conflict Between Whitney and Cook

24 Florida Tax Review 375 (2021)
Number of pages: 49 Posted: 09 Jun 2020 Last Revised: 22 Nov 2022
H. David Rosenbloom and Fadi Shaheen
Caplin & Drysdale, Chartered and Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 299 (199,022)

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Treaty override, harmonization, inconsistency, repugnancy, conflict, clear statement, specific-over-general canon of construction, Supremacy Clause, statute, treaty, tax treaties

5.

On Fixing U.S. International Taxation

Jerusalem Review of Legal Studies (Oxford University Press, 2013) Forthcoming
Number of pages: 11 Posted: 10 Nov 2013 Last Revised: 29 Nov 2013
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 265 (226,116)

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International taxation, international tax neutrality, deferral, foreign tax credit, foreign tax deductions, tax rate, foreign source income

6.

The TCJA and the Treaties

95 Tax Notes International 1057 (September 2019) , Rutgers Law School Research Paper
Number of pages: 14 Posted: 11 Oct 2019
H. David Rosenbloom and Fadi Shaheen
Caplin & Drysdale, Chartered and Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 253 (236,726)

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international tax, participation exemption, GILTI, transition tax, hybrid transactions, hybrid entities, FDII, income tax treaties, treaty override, treaty reconciliation, nondiscrimination, foreign tax credit

7.

How Reform-Friendly Are U.S. Tax Treaties?

Number of pages: 52 Posted: 09 Feb 2016 Last Revised: 22 May 2017
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 245 (243,378)

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international tax, tax treaties, treaty compatibility, reform proposals, double taxation, credit, exemption, deduction

8.

Income Tax Treaty Aspects of Nonincome Taxes: The Importance of Residence

71 Tax Law Review 583 (Spring 2018)
Number of pages: 41 Posted: 02 Nov 2018
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 204 (289,619)

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Tax, treaty, residence, nonincome tax, retail sales tax, value added tax (VAT), flat tax, X tax, destination-based cash flow tax (DBCFT), turnover tax, tax on income, comprehensive taxation, nondiscrimination

9.

Understanding Lockout

69 Tax Law Review 231 (2016)
Number of pages: 44 Posted: 29 Jul 2015 Last Revised: 25 Jun 2016
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 191 (307,523)

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International tax, deferral, lockout, new view, full value model, real income, book income, GAAP, efficiency costs

10.

Toulouse: No Treaty-Based Credit?

104 Tax Notes Int'l 417 (Oct. 25, 2021)
Number of pages: 6 Posted: 23 Nov 2021
H. David Rosenbloom and Fadi Shaheen
Caplin & Drysdale, Chartered and Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 140 (400,450)

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treaty-based foreign tax credit, net investment income tax, IRAP, international tax, income tax treaties, harmonization

11.

Is the UTPR a 100 Percent Tax on a Deemed Distribution?

181 Tax Notes Federal 481 (2023) / 112 Tax Notes International 313 (2023), Rutgers Law School Research Paper
Number of pages: 7 Posted: 05 Dec 2023
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 65 (660,774)

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UTPR, GloBE, Pillar 2, international tax, tax treaties

12.

Whirlpool: Law or Policy?

176 Tax Notes Federal 959 (2022)
Number of pages: 13 Posted: 29 Sep 2022
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 46 (770,922)

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Subpart F, foreign base company sales income, FBCSI, branch rule, sales branch, manufacturing branch

13.

Brief of Amici Curiae in Christensen v. United States

Rutgers Law School Research Paper Forthcoming
Number of pages: 17 Posted: 11 Jul 2024
H. David Rosenbloom and Fadi Shaheen
Caplin & Drysdale, Chartered and Rutgers, The State University of New Jersey - School of Law, Newark
Downloads 35 (852,838)

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14.

International Tax Neutrality: Revisited

Tax Law Review, Vol. 64, p. 131 (2011)
Posted: 27 May 2013
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark

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International tax, tax policy, efficiency, capital export neutrality (CEN), capital import neutrality (CIN), national neutrality (NN), capital ownership neutrality (CON), national ownership neutrality (NON), source-based taxation, residence-based taxation, territorial, worldwide

15.

International Tax Neutrality: Reconsiderations

Virginia Tax Review, Vol. 27, p. 203, 2007
Posted: 27 May 2013
Fadi Shaheen
Rutgers, The State University of New Jersey - School of Law, Newark

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International tax, tax policy, efficiency, capital export neutrality (CEN), capital import neutrality (CIN), national neutrality (NN), capital ownership neutrality (CON), national ownership neutrality (NON), source-based taxation, residence-based taxation, territorial, worldwide