International Tax as International Law: An Analysis of the International Tax Regime » (New Edition)

Reuven S. Avi-Yonah is the Irwin I. Cohn Professor of Law and Director of the International Tax LLM Program and the Michigan-Tsinghua Exchange Program at the University of Michigan Law School. Dr Avi-Yonah graduated from the Hebrew University in 1983, received his Ph.D. in history from Harvard University in 1986, and received a JD from Harvard Law School in
1989. He practiced tax law in Boston and New York until
1993. He became an Assistant Professor of Law at Harvard Law School in 1994 and moved to the University of Michigan in
2000. He has published numerous articles on domestic and international tax issues and is the author of six other tax books. He has served as consultant to the U.S. treasury and the OECD on tax competition issues and has been a member of the executive committee of the New York State Bar Association Tax Section and of the Advisory Board of Tax Management, Inc. He is currently a member of the Steering Group of the OECD International Network for Tax Research and Chair of the ABA Tax Section VAT Committee.

This book explains the international tax regime and how U.S. tax law plays in the international regime.

Introduction: Is there an international tax regime? Is it part of international law?     1
Jurisdiction to tax     22
Sourcing income and deductions     38
Taxation of nonresidents: Investment income     64
Taxation of nonresidents: Business income     79
Transfer pricing     102
Taxation of residents: Investment income     124
Taxation of residents: Business income     150
The United States and the tax treaty network     169
Tax competition, tax arbitrage, and the future of the international tax regime     182
Bibliography     189
Index     205