Thinker, Teacher, Traveler: Reimagining International Tax
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The scholarly contributions to this Festschrift reflect David Rosenbloom’s significant influence on international taxation and its community, both academic and professional.
Why This Book?
This Festschrift celebrates the work of David Rosenbloom and marks the occasion of his 80th birthday. Throughout his illustrious career, David has developed many close friendships in practice, government and academia, and his creativity and dedication have contributed immeasurably to the field of international taxation. David has also shaped the success of others, particularly alumni of NYU’s International Tax Program.
Members of David’s truly global network wrote the scholarly essays that make up this Festschrift. Their contributions engage David’s large body of written work, his government service and his professional career, and they demonstrate his impact on the lives and careers of those fortunate enough to have worked and studied with him. The book reflects David’s significant influence on international tax and his natural ability to draw people together from the world over and to cultivate their intellectual curiosity.
Thinker, Teacher, Traveler
DOI: https://doi.org/10.59403/k6dp6c
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Chapter 1: FATCA – A Curse or a Blessing?
DOI: https://doi.org/10.59403/k6dp6c001
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Chapter 2: Reciprocity as a Fundamental Principle of Tax Treaties: Meaningless Platitude, Interpretive Guideline or Misguided Policy?
DOI: https://doi.org/10.59403/k6dp6c002
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Chapter 3: Tax Treaty Arbitration: A Reassessment
DOI: https://doi.org/10.59403/k6dp6c003
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Chapter 4: Globalization, Tax Competition and the Fiscal Crisis of the Welfare State: A Twentieth Anniversary Retrospective
DOI: https://doi.org/10.59403/k6dp6c004
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Chapter 5: The Morality – or Immorality – of International Tax Planning
DOI: https://doi.org/10.59403/k6dp6c005
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Chapter 6: Double Taxation Relief under the OECD Model: Time to Update?
DOI: https://doi.org/10.59403/k6dp6c006
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Chapter 7: The Legislative Role of Tax Regulations – A Plea in the Time of Pandemic
DOI: https://doi.org/10.59403/k6dp6c007
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Chapter 8: A Good Example? The Increasing Use of Examples in the OECD Model Commentaries
DOI: https://doi.org/10.59403/k6dp6c008
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Chapter 9: Wouldn’t It Be Nice: Reimagining US Taxation of Outbound Investment
DOI: https://doi.org/10.59403/k6dp6c009
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Chapter 10: Attribution Across Borders – From CFC Rules to Pillar Two
DOI: https://doi.org/10.59403/k6dp6c010
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Chapter 11: Taxation of Cryptocurrency: Emerging Inconsistencies and Challenges in the United States and Brazil
DOI: https://doi.org/10.59403/k6dp6c011
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Chapter 12: Transfer Pricing Money bis
DOI: https://doi.org/10.59403/k6dp6c012
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Chapter 13: Taxing Business Profits – A Historical UK Perspective
DOI: https://doi.org/10.59403/k6dp6c013
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Chapter 14: Notes on Equal Treatment and Non-Discrimination – The OECD Model Convention: Is there a Need for a Change?
DOI: https://doi.org/10.59403/k6dp6c014
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Chapter 15: Why Optimal Unilateral Tax Strategies are a Prerequisite for Multilateral Cooperation in the Era of BEPS
DOI: https://doi.org/10.59403/k6dp6c015
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Chapter 16: Arbitration after BEPS
DOI: https://doi.org/10.59403/k6dp6c016
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Chapter 17: Global Minimum Taxation (GloBE): What Is It About and What Could be a European Answer?
DOI: https://doi.org/10.59403/k6dp6c017
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Chapter 18: Then and Now
DOI: https://doi.org/10.59403/k6dp6c018
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Chapter 19: Transfer Pricing: History, Lessons and Experiences as a Litigator
DOI: https://doi.org/10.59403/k6dp6c019
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Chapter 20: Will Digital Services Taxes Start a Global Trade War?
DOI: https://doi.org/10.59403/k6dp6c020
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Chapter 21: Credit Where Credit Is Due: Partial Exemptions as Implicit Foreign Tax Credit Limitations?
DOI: https://doi.org/10.59403/k6dp6c021
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Chapter 22: Fowler v. Commissioners for Her Majesty’s Revenue and Customs: Some Thoughts on Tax Treaty Interpretation
DOI: https://doi.org/10.59403/k6dp6c022
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Chapter 23: Some Key Elements of International Investment Agreements with Potential Tax Impacts for Developing Countries
DOI: https://doi.org/10.59403/k6dp6c023
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Chapter 24: A Deserved Tribute
DOI: https://doi.org/10.59403/k6dp6c024
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Chapter 25: Counteracting Tax Treaty Abuses from a European Perspective: Frictions and Interactions between the OECD PPT and the ATAD GAAR
DOI: https://doi.org/10.59403/k6dp6c025
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Chapter 26: Has Cross-Border Arbitrage Met Its Match?
DOI: https://doi.org/10.59403/k6dp6c026
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Chapter 27: HNWIs and Exit Tax in Japan – Developments in the Digital Age
DOI: https://doi.org/10.59403/k6dp6c027
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Chapter 28: Information upon Request under Double Taxation Conventions: Lessons Learned from the Swiss “Laboratory”
DOI: https://doi.org/10.59403/k6dp6c028
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Chapter 29: Revisiting the Question: “Why Not Des Moines?”
DOI: https://doi.org/10.59403/k6dp6c029
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Chapter 30: Digital Services Taxes and Tax Treaties
DOI: https://doi.org/10.59403/k6dp6c030
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Chapter 31: The Unbearable Lightness of the Limitations to Excessive Tax Burdens in the European Convention on Human Rights
DOI: https://doi.org/10.59403/k6dp6c031
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Chapter 32: Dispute Prevention as the New Focus in International Tax Disputes
DOI: https://doi.org/10.59403/k6dp6c032
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Chapter 33: US Tax Treaty Limitation on Benefits Rules
DOI: https://doi.org/10.59403/k6dp6c033
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Chapter 34: The Need for an Efficient and Effective Alternative Dispute Resolution Mechanism in International Taxation
DOI: https://doi.org/10.59403/k6dp6c034
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Chapter 35: Some Thoughts about the Inclusion of a Saving Clause in the OECD Model
DOI: https://doi.org/10.59403/k6dp6c035
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Chapter 36: Is There Finally an International Tax System?
DOI: https://doi.org/10.59403/k6dp6c036
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Chapter 37: Practicability, Enforcement and Legitimacy: Tax Treaty Dispute Resolution at a Crossroads
DOI: https://doi.org/10.59403/k6dp6c037
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Chapter 38: The Reach of Inapplicable Treaties
DOI: https://doi.org/10.59403/k6dp6c038
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Chapter 39: A Fox among Hedgehogs
DOI: https://doi.org/10.59403/k6dp6c039
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Chapter 40: Legal Fictions, Elections and Tax Law Boundaries
DOI: https://doi.org/10.59403/k6dp6c040
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Chapter 41: Digital Taxation – Pillar One from a Developing Country Perspective
DOI: https://doi.org/10.59403/k6dp6c041
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Chapter 42: US Tax Policy and Attribution of Profits to PEs
DOI: https://doi.org/10.59403/k6dp6c042
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Chapter 43: An Insider’s View
DOI: https://doi.org/10.59403/k6dp6c043
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Chapter 44: Jurisdiction, Legal Fictions and the Tax State
DOI: https://doi.org/10.59403/k6dp6c044
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Chapter 45: The Future of International Tax Disputes: The Inevitability of Fusion
DOI: https://doi.org/10.59403/k6dp6c045
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Chapter 46: Direct Taxation of the Digitalized Economy: Towards a Simplified Income Tax Model for Market Economies
DOI: https://doi.org/10.59403/k6dp6c046
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Chapter 47: Tax Morality – The New Frontier?
DOI: https://doi.org/10.59403/k6dp6c047
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Chapter 48: A Blueprint for Restructuring the OECD Model’s Distributive Rules
DOI: https://doi.org/10.59403/k6dp6c048
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Chapter 49: Tax and Investment Treaties: A Few Observations
DOI: https://doi.org/10.59403/k6dp6c049
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Chapter 50: David Rosenbloom: Inspiring Generations of Tax Lawyers
DOI: https://doi.org/10.59403/k6dp6c050
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Chapter 51: David Rosenbloom: A Custodian of the First and Continuing “Real” Model Tax Treaty
DOI: https://doi.org/10.59403/k6dp6c051
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Chapter 52: Practical Issues in the Context of Treaty Entitlement through Fiscally Transparent Vehicles
DOI: https://doi.org/10.59403/k6dp6c052
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Georg Kofler is a professor of international taxation at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), Austria. At NYU, he graduated from the International Tax Program in 2004, served as an acting assistant professor from 2006 to 2008 and became a global professor of law in 2019.
Ruth Mason is the Edwin S. Cohen Distinguished Professor of Law and Taxation at the University of Virginia School of Law. She was an acting assistant professor at NYU from 2005 to 2006.
Alexander Rust is a professor of international tax law at WU (Vienna University of Economics and Business) in Austria. He completed the International Tax Program at NYU in 2007 and was an acting assisting professor at NYU from 2008-2009.
Peter R. Altenburger, Brian J. Arnold, Hugh J. Ault, Reuven S. Avi-Yonah, Mateus Calicchio Barbosa, Peter A. Barnes, Mary Bennett, Peter H. Blessing, Eduardo Brandt, Yariv Brauner, Jonathan S. Brenner, Chloe Burnett, Flávia Cavalcanti, Luzius Cavelti, Josiah P. Child, Graeme Cooper, Malcolm Gammie, Juan Carlos Garantón-Blanco, Carlo Garbarino, Werner Haslehner, Johanna Hey, Thomas Horst, Porus F. Kaka, Young Ran (Christine) Kim, Michael Kobetsky, Georg Kofler, Michael Lang, Michael Lennard, Juan Manuel López Durán, Donald C. Lubick, Guglielmo Maisto, Ruth Mason, Yoshihiro Masui, Lauren Moses, Huzefa Mun, Raúl Navarro Becerra, Xavier Oberson, Paul Oosterhuis, Pasquale Pistone, Marcello Poggioli, Natalia Quiñones, Diego Quiñones, Richard L. Reinhold, Ricardo Rendón Pimentel, Alexander Rust, Pascal Saint-Amans, Wolfgang Schön, Luís Eduardo Schoueri, Fadi Shaheen, Daniel Shaviro, Stephen E. Shay, Sam Sim, Robert B. Stack, John P. Steines, Jr., Miranda Stewart, Niv Tadmore, Guillermo O. Teijeiro, Ana Cláudia Akie Utumi, Juan Lopez Valek, Kees van Raad, Stef van Weeghel, Richard Vann, Philip R. West, J. Scott Wilkie, Omar Zuñiga.
