Number 6 - 2007 contains the following:
 

This article reviews some of the major differences between the new (2006) and old (1996) US Models, as well as some of the major differences between the new US Model and the current (2005) OECD Model Tax Convention. The article also discusses some new trends in US treaty policy which are not reflected in the new US Model. The article concludes by evaluating the new US Model in light of the emerging trend to use tax treaties not only to prevent double taxation, but also to combat double non-taxation.

This article traces the evolution of the French concept of abuse of law and compares it to the EU notion of abusive practices. Specifically, the article examines the new French definition of abuse of rights that has emerged as a result of three major decisions, two by the French Conseil d'Etat and one by the European Court of Justice. The article presents the factual background and reasoning of each decision and explains how the decisions have contributed to a clearer definition of the French concept of abuse of rights. The article also considers the impact of the ECJ's decision in Cadbury Schweppes.

The taxation of offshore portfolio investment by New Zealand residents has been a controversial area of New Zealand's tax law since 1980, when the foreign investment fund (FIF) rules were first enacted. Dissatisfaction with the 1992 FIF rules resulted in the managed funds industry lobbying in the late 1990s for the rules to be changed. Subsequently, a review of New Zealand's tax regime by an independent committee in 2001 placed the taxation of offshore portfolio investment back on the reform agenda, which led the government to announce proposals for new FIF rules in the 2005 Budget. These proposals were met with almost total condemnation by the affected parties and, after extensive consultation throughout 2006, the New Zealand Parliament enacted new FIF rules in December 2006 which were substantially different from those outlined in the 2005 Budget. The new rules apply to most offshore portfolio investment by New Zealand residents as from 1 April 2007. This article reviews the extensive history of the new FIF rules and critically evaluates whether they are likely to solve the problems they were designed to overcome.