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U.S. Tax Treaty Policy and the European Court of Justice


Ruth Mason


University of Virginia School of Law


Tax Law Review, Vol. 59, 2005

Abstract:     
This Article considers the effects of EC law on U.S. tax treaty policy. The discussion is framed by the controversy over the legality of tax treaty limitation on benefits clauses (LOBs) in the wake of recent ECJ decisions, and it argues that U.S. tax treaty policy is on a collision course with the tax jurisprudence of the ECJ.

Number of Pages in PDF File: 85

Keywords: International tax, tax harmonization, multitlateral tax treaty, European Union, tax treaties, limitation on benefits, European Court of Justice, tax policy, Open Skies, Member State sovereignty, treaty shopping, qualification conflicts

JEL Classification: H20, H29, H26, H79, H74, H89

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Date posted: September 12, 2005 ; Last revised: February 27, 2013

Suggested Citation

Mason, Ruth, U.S. Tax Treaty Policy and the European Court of Justice. Tax Law Review, Vol. 59, 2005. Available at SSRN: http://ssrn.com/abstract=796966

Contact Information

Ruth Mason (Contact Author)
University of Virginia School of Law ( email )
580 Massie Road
Charlottesville, VA 22903
United States
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