Answering the Right Questions in Rawat

Authors

Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow

Document Type

Article

Publication Date

2024

Abstract

The Rawat case, which is currently before the D.C. Circuit, has generated a huge amount of commentary. The problem is that much of this commentary has focused on the partnership tax issues in the case and not on the international tax issue, which is the source of the relevant income. In my opinion, the international tax issue should be dispositive.

Comments

Reprinted with the permission of Tax Analysts.

Recommended Citation

Avi-Yonah, Reuven S. "Answering the Right Questions in Rawat." Tax Notes International 113, no. 12 (2024): 1675-1678.