Based on an analysis of 3,844 tax treaties, the Vienna Convention on the Law of Treaties and its Commentaries (VCLT), and case law of various domestic and international courts.The current orthodoxy maintains that courts are not required to compare all language texts of a plurilingual treaty but...

Different in more ways than it is possible to easily enumerate, the formation of the United States and the European Union (EU) had a striking similarity of purpose: to increase citizens' welfare by uniting a collection of independent states, each with its own politics, culture, and economy. Of...

Fiscal disparities occur when economic resources and public service needs are unevenly distributed across localities. There are two equity concerns associated with fiscal disparities. First, as Yinger (1986) shows, it is not considered fair to require two otherwise-identical households to pay a...

This article considers whether the fundamental freedoms of the EC Treaty encompass an absolute requirement on the Member States to mitigate double taxation, and it concludes that such a requirement could reasonably be inferred from the goals of the fundamental freedoms and the European Court of...

Over the past century, Florida has grown and prospered largely due to a constant influx of wealthy retirees. The state has achieved this status not by accident, but rather by design. For nearly a century, Florida has worked to position itself as a domestic tax haven. By exploiting its...

The Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) dealt a fiscal blow to state governments by repealing the state death tax credit, a mechanism by which the Federal government effectively shared estate tax revenues with the states. Between 2001 and 2005, the repeal gradually...

We study U.S. state tax rules over the past 70 years to shed light on the determinants of U.S. state tax policy, generating three key results. First, we show that long-term tax trends are not consistent with Tiebout sorting and race-to-the-bottom competition models. Second, we document evidence...

We develop a model with two provinces, producing two goods: one mobile and the other not. The mobile good is taxed according to the destination principle by the local government; it is also federally taxed. People decide to buy the good at the most advantageous price. Namely they can buy...

Adam S. Wallwork is an attorney in the public finance and tax departments of Ballard Spahr LLP in Washington, D.C. In this article, Wallwork shows how tax reform has affected the municipal bond market and why Republicans should care