International Tax

U.S. Estate and Gift Tax Treaties (Portfolio 6896)

  • This Portfolio describes the purpose, operation, and construction of the 17 estate and gift transfer tax treaties

Description

The Tax Portfolio, U.S. Estate and Gift Tax Treaties, is divided into six parts. Part I: Introduction, explains the purpose and types of transfer tax treaties. Part II: Situs-Type Treaties, describes when situs-type transfer tax treaties apply and explains how a situs-type treaty assigns primary taxing jurisdiction to one country. It also analyzes the effect that situs-type treaties have on the deductions and credits of treaty countries. Part III: Domicile-Type Treaties, describes when domicile-type treaties apply and how these treaties assign primary taxing jurisdiction. It also analyzes the situs rules that are incorporated into domicile-type treaties, the effect that domicile-type treaties have on the deductions, exemptions, and credits of treaty countries, and the general operation of the treaties’ nondiscrimination provisions. Part IV: Special, Administrative, and Enforcement Provisions, discusses the ways in which transfer tax treaties enable a treaty country to enforce the collection of death taxes and exchange information with the other country, as well as issues that a taxpayer subject to a treaty may face in reporting income. Part V: Treaty Interpretation, sets forth the principles of treaty interpretation and construction. Part VI: Particular Treaty Analysis, discusses the details of each transfer tax treaty.

Table of Contents

I. Introduction
II. Situs-Type Treaties
III. Domicile-Type Treaties
IV. Special, Administrative, and Enforcement Provisions
V. Treaty Interpretation
VI. Particular Treaty Analysis

schoenblum-jeffrey-2015
Jeffrey Schoenblum
Centennial Professor Of Law
Vanderbilt University School Of Law
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