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
Reuven S. Avi-Yonah and Oz Halabi, "U.S. Treaty Anti-Avoidance Rules: An Overview and Assessment" (January 2012). University of Michigan Program in Law and Economics. Working Paper 45.