The Fog: The Interaction of Treaties & Domestic Tax Law

Attorney Michael Karlin presented a panel titled "The Fog: The Interaction of Treaties & Domestic Tax Law" at the American Bar Association Tax Section Midyear Tax Meeting. This comprehensive session covered the relationship of tax treaties and domestic law, as well as Section 960 – Tax Treaties and Indirect Tax Credits, Section 1411 – The Net Investment Income Tax, Section 7701(b) – Tax Treaties and Residence, Section 864(c)(8) – Sale of Partnership Interest by Foreign Person, Section 877A(f) Distributions from Non-Grantor Trusts to Covered Expatriates and Section 2801 – Taxation of Gifts to and Inheritances Received by U.S. Persons from Covered Expatriates.

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