Interpretation And Application Of Tax Treaties In North America

This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.

This article examines the influence, if any, of the Preamble and article 6(1) of the OECD Multilateral Instrument (MLI), with particular focus on the extent to which they will modify the interpretation and application of the existing tax treaties in Canada, Costa Rica and Mexico.

Text originally prepared for a class. Includes course outline, assignments and supporting materials.

Distributed to some depository libraries in microfiche.