International Tax Reform: Response to Sheppard

2 Pages Posted: 3 Aug 2008

Date Written: December 17, 2007

Abstract

In the Dec. 10, 2007, issue of Tax Notes, Contributing Editor Lee Sheppard stated that the treaty benefits provision in the Tax Reduction and Reform Act of 2007 (H.R.3970, sec. 3204) was essentially the same as the Doggett provision in sec. 12001 of the farm bill, H.R.2419. I analyze the relevant statutory language to argue that the two are diametrically different for U.S. treaty partners.

Keywords: tax, tax treaty, limitation on benefits, Doggett, Rangel, 2419, 3970, Sheppard, withholding, Farm Bill

JEL Classification: K33, K34

Suggested Citation

Tittle, Martin B., International Tax Reform: Response to Sheppard (December 17, 2007). Tax Notes, Vol. 117, No. 12, 2007, Available at SSRN: https://ssrn.com/abstract=1196402

Martin B. Tittle (Contact Author)

Law Office of Martin B. Tittle ( email )

P.O. Box 1541
Ann Arbor, MI
United States
734-846-3864 (Phone)

HOME PAGE: http://www.martintittle.com

Do you have negative results from your research you’d like to share?

Paper statistics

Downloads
93
Abstract Views
757
Rank
502,565
PlumX Metrics