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Interpretation and Application of Tax Treaties in North America



The interpretation of tax treaties has never been easy. Sometimes we simply need to understand the mentality of the person when they interpret and apply a tax treaty. For example, what can be good faith for some people can be treaty override for their counterparts. Certainly the courts in Canada, the United States and Mexico have reasoned all of their tax treaty interpretation cases in a different manner. Thus, it is possible that if a case is resolved in one court, the ruling may be different had the same case been brought to a court in another country. More than 100 countries have a tax treaty concluded with Canada, the United States or Mexico. As such, it is helpful for tax practitioners worldwide to understand the criteria used by the courts in these countries when interpreting a tax treaty. This book presents the reader with an in-depth overview of the materials, court cases and mutual agreement procedures implemented in these three countries. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties.


Detail Information

Call Number
17 INT jua
Publisher IBFD : Amsterdam.,
Collation
xiv, 284 p.; 23 cm.
Language
English
Classification
17 INT jua
ISBN/ISSN
978-90-8722-019-8
Edition
-
Subject(s)
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