Who Invented the Single Tax Principle? An Essay on the History of US Treaty Policy
Reuven S. Avi-Yonah
University of Michigan Law School
January 28, 2014
U of Michigan Public Law Research Paper No. 318
The first US tax treaty with France in 1932 reduced US withholding taxes at a time when France was a purely territorial jurisdiction, which meant that US source income would be taxed neither by the US nor by France. Current US and OECD treaty policy, on the other hand, is to prevent such double non-taxation by conditioning the reduction of source based taxation on the income being taxed in the state of residence. This paper traces how the “single tax principle” (income should be taxed not more or less than once) made its way into the tax treaties and became a foundational element of the international tax regime.
Number of Pages in PDF File: 9
Keywords: Tax Treaties, Limitation on Benefits, Tax History
JEL Classification: H20
Date posted: March 1, 2013 ; Last revised: February 4, 2014
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