In this article, the authors provide a summary of the anti-avoidance rules in the United States that relate to bilateral tax treaties. Specifically, they focus on treaty-based anti-avoidance rules and discuss whether or not a General Anti-Avoidance Rule would be appropriate in this context.
Date of this Version
Working Paper Citation
Avi-Yonah, Reuven S. and Halabi, Oz, "U.S. Treaty Anti-Avoidance Rules: An Overview and Assessment" (2012). Law & Economics Working Papers. 45.