One Thomas Circle, N.W.
Washington, DC 20005
Caplin & Drysdale, Chartered
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
International Taxation, Tax Competition, International Cooperation
international tax, participation exemption, GILTI, transition tax, hybrid transactions, hybrid entities, FDII, income tax treaties, treaty override, treaty reconciliation, nondiscrimination, foreign tax credit
Treaty override, harmonization, inconsistency, repugnancy, conflict, clear statement, specific-over-general canon of construction, Supremacy Clause, statute, treaty, tax treaties
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