Why this book?
The book `Interpretation and Application of Tax Treaties in North America' provides a comprehensive analysis of the tax treaty policy, court cases, competent authority agreements and other relevant tax treaty information from Canada, Mexico and the United States. It is divided into three sections: Section I presents the origins and development of tax treaty law and the general treaty interpretation principles. The work carried out by the League of Nations and the OECD’s ultimate codification of customary tax treaty practice are discussed, followed by a discussion of the public international law principles that have been applied to tax treaty situations. Section II presents the general tax treaty interpretation approach, as well as the specific interpretation and application principles which have been applied in Canada, Mexico and the United States. Finally, Section III presents potential solutions and conclusions.
Nearly 100 countries have concluded tax treaties with Canada, Mexico or the United States. Therefore, this book is an important addition to the library of any tax practitioner interested in knowing how a tax treaty situation would be interpreted in these countries.
Juan Angel Becerra has more than 20 years experience as an international tax adviser specializing in cross-border mergers and acquisitions and financial transactions. He is a frequent speaker in international tax seminars in Mexico, the United States and Europe, and more recently for the revenue authorities of Canada and Mexico.