INTRODUCTION

This research guide is a starting point for research on international and foreign tax law research. It describes resources for researching model, U.S., and non-U.S. tax treaties and all sources of foreign tax law. Throughout this guide the word "treaty" is used to describe all types of international agreements, including both formal treaties and executive agreements.

This guide does not cover customs or tariff law. For information on customs law, please consult:

• Customs Law (U.S.) Research Guide
• Customs Law (International) Research Guide

For information on locating U.S. tax statutes, regulations, and cases, including those related to U.S. taxation of international income and persons, see the Library's Federal Tax Research Guide.

For more information on international law research generally, see:

• International and Foreign Law Basics Research Guide 
• Treaty Research Guide

SECONDARY SOURCES

If you are beginning your international tax law research from scratch (that is, you have no citations to applicable treaties or other primary sources), or if you don't understand the primary sources you've already found, secondary sources may be extremely helpful.

1. Treatises, Handbooks & Dictionaries.

Below is a list of selected international tax law treatises, handbooks, and dictionaries available in the Georgetown Law Library or through its subscription databases (including Westlaw and Lexis). You can find other works by searching the library's catalog, GULLiver.

• International Taxation
  • Boris I. Bittker & Lawrence Lokken, Fundamentals of International Taxation: U.S. Taxation of Foreign Income and Taxpayers. (2012) [KF6419 .B51 2012].
  • Richard L. Doernberg, International Taxation in a Nutshell (9th ed. 2012). [KF6419.Z9 D64 2012]
    
  • • Brief introduction to U.S. taxation of U.S. taxpayers with foreign income and foreign taxpayers with U.S. income.
  • Richard M. Hammer, Cym H. Lowell, Marianne Burge, and Marc M. Levey, International Transfer Pricing: OECD Guidelines (1998- ).
    • Available electronically through Westlaw [WGL-ITPOECD] and Checkpoint; (Choose "International" from the dropbox. The book is under Editorial Materials - WG&L Treatises).
  • International Bureau of Fiscal Documentation, IBFD International Tax Glossary (Rev. 6th ed. 2009). [HJ121 .I58 2009] and electronically on IBFD.
    
  • Denis A. Kleinfeld, Langer on Practical International Tax Planning (2000- ; loose-leaf for updating). [K4464.5 .L362 2000].
  • Joel D. Kuntz & Robert J. Peroni, U.S. International Taxation (1991- ; loose-leaf for updating). KF6419 .K86 1991.
    • Also available electronically through Westlaw [WGL-INTTAX] and Checkpoint; (Choose "International" from the dropbox. The book is under Editorial Materials - WG&L Treatises).
  • Cym Lowell, Marianne Burge, and Peter Briger, U.S. International Transfer Pricing (1998- ).
    • Available electronically through Westlaw [WGL-ITP] and Checkpoint; (Choose "International" from the dropbox. The book is under Editorial Materials - WG&L Treatises).
  • Andrew Lymer and John Hasseldine eds., The International Taxation System (2002). [K4475 .I58 2002].
  • Roy Rohatgi, Basic International Taxation (2d ed. 2005). [K4475 .R64 2005] and electronically.
    
  • • Covers not only U.S. international taxation, but international tax concepts generally.
  • Rufus von Thülen Rhoades & Marshall J. Langer, U.S. International Taxation and Tax Treaties (2001- ; loose-leaf for updating). [KF6419 .R48]. Includes the full text of U.S. tax treaties and agreements.
    • Also available electronically through Lexis: Rhoades & Langer U.S. International Taxation & Tax Treaties.
  • For other titles, try the following subject searches in GULLiver:
    • Double taxation
    • Income tax - Foreign income
    • International business enterprises - Taxation - Law and legislation
    • Tax havens
• Foreign & Comparative Taxation
  • BNA Foreign Income Tax Management Portfolios. BNA publishes loose-leaf handbooks to the tax laws of many individual foreign countries.
    • Print: [KF6297 .B952], portfolio nos. 950 to 999.
    • Lexis: BNA Tax Management Portfolios - Foreign Income Series.
    • Westlaw: TM-FOR
    • BNA Tax Management Portfolio Collection 
    • Bloomberg Law
      
  • Victor Thuronyi, Comparative Tax Law (2003). [K4460 .T48 2003].
  • For other titles, try a keyword search in GULLiver for taxation and comparative law or taxation and [country name] (e.g., taxation and argentina).

2. Current Awareness/Periodicals.

The following resources are useful for monitoring current developments in international taxation. They may also provide in-depth analysis of legal issues too current to be covered in treatises.

• Tax Analysts' Tax Notes International. Published weekly. Tax news and both scholarly and practitioner-focused articles.
  • Print: K4471.2 .T3 (1989 - )
  • Tax Analysts (1989 - )
    
  • Lexis: Tax Analysts Tax Notes International Magazine. (1992 - )
• Tax Analysts' Worldwide Tax Daily.
  
• • Tax Analysts (1987 - )
    
  • Lexis: Tax Analysts Worldwide Tax Daily. (June 1984 - )
    
• BNA International Tax Monitor (2001 - ) Daily newsletter.
• BNA Tax Management Transfer Pricing Report (1992 - ) Bi-weekly newsletter.
• International Transfer Pricing Journal. Monthly publication of the International Bureau of Fiscal Documentation
• • Print: K9 .N894 (1993 - 2008; library cancelled print subscription).
  • Electronic: IBFD (1999 - )
    
• Journal of International Taxation (Warren, Gorham & Lamont). Monthly journal featuring in-depth articles.
• • Print: K10 .O451 (1990 - )
  • Checkpoint (1991 - ) (Choose "International" from the dropbox. The journal is under News/Current Awareness - WG&L Journals).
    
  • Westlaw: WGL-JITAX (1990 - )
    
• Tax News Service. Weekly newsletter published by the International Bureau of Fiscal Documentation. Reports on recent developments in taxation throughout the world.
• • Print: K4456.3 .I58 (2006 & 2007 only).
  • Electronic: IBFD (1988 - )

TREATIES & INTERNATIONAL AGREEMENTS

For more information about researching treaties see the Library's Treaty Research Guide. 

There are three types of treaties of interest to U.S. international tax law researchers: model tax treaties, U.S. tax treaties, and non-U.S. tax treaties.

1. Model Treaties

Model tax treaties are "form" treaties used as a basis for negotiation between nations. They are not binding in and of themselves. They are often accompanied by commentaries or technical explanations that aid in their interpretation. The United States promulgates model treaties on income tax, estate and gift tax, and the exchange of tax information. Other organizations that promulgate model tax treaties are the Organisation for Economic Co-operation & Development (OECD) and the United Nations. Note that superseded model treaties (e.g., the 1963 OECD Model Income Tax Treaty) and their commentary are still useful guides to the interpretation of in-force treaties that were based upon them.

• Major Model Taxation Treaties:
  • OECD Model Treaties
    • OECD Model Convention with Respect to Taxes on Income and on Capital (condensed version) (2005 - ) K4473.25 .O74.
    • 1963 and 1977 OECD Model Income Tax Treaties and Commentaries: A Comparative Presentation (1987). K4475.4 .A14 1987.
    • Note: The OECD has also promulgated model agreements on the exchange of information in tax matters, estate taxation, and other subjects. Consult the databases listed below for the full text of these other model treaties.
  • United Nations Model Double Taxation Convention Between Developed and Developing Countries (also known as the United Nations Model Income & Capital Tax Convention)
    
    • 2011:
    • • Print: K4473.6 .U5 2012
      • Web: United Nations Model Double Taxation Convention
        
    • 2001: K4473.6 .U5 2001.
    • 1980: K4473.6 .U5 1980.
  • United States Model Income Tax Convention
    • 2006 Text
    • 2006 Technical Explanation
    • 1996 Text
    • 1996 Technical Explanation
    • Note: The United States has also promulgated model agreements on estate and gift taxation and the exchange of tax information. Consult the databases listed below for the full text of these other model treaties.
• Databases & Loose-leaf Services: 
  • Lexis. Lexis is the best source of model tax treaties available to GULC users, because it offers the most comprehensive and current collections of model tax treaties.
    • Tax Analysts Worldwide Tax Treaties Model Tax Treaties. Searchable database of model tax treaties, including commentary. Coverage: July 1, 1943 - present.
    • Tax Analysts Worldwide Tax Treaties Model Convention Documents. Browsable list of model tax treaties, including commentary. Coverage: April 5, 1923 - present.
    • Tax Analysts Worldwide Tax Treaties. Browsable list of world tax treaties, including model treaties (look under organization name, e.g., OECD). Coverage: 1828 - present.
  • Other Sources. Use these sources with caution, because they do not always provide the most recent version of any given model tax treaty:
    • IBFD (1963 -- )
      
    • Checkpoint (Choose "International" from the dropbox. Under Primary Source Materials - Tax Treaties - U.S. Tax Treaties (WG&L). Then select "United States" from the table of contents so view the model treaties).
      
    • CCH Tax Treaties Reporter. KF6306 .C6 (library cancelled print subscription in 2008).
    • CCH Tax Research Network (International Tax tab, U.S. Tax Treaties Reporter database).
      

2. United States Treaties

United States tax treaties are treaties to which the United States is a party. Most U.S. tax treaties are bilateral agreements for the avoidance of double taxation. For sources of U.S. model tax treaties, see Model Treaties, above.

• Treaty Sources:
  • IRS Web Site. This is a good, free source for current treaties.
  • Internal Revenue Bulletin. Often the first place U.S. tax treaties are printed. This source includes Executive Reports and Treasury Department technical explanations prepared for the Senate. When available, tax treaties and committee reports are located in part II.
  • • Print: KF6301 .A12 (1992 -- )
      
    • Electronic: IRS (1996 -- ) 
  • Cumulative Bulletin. KF6301 .A1 (1969 - ). The Cumulative Bulletin (CB) reprints treaty text and includes Executive Reports and Treasury Department technical explanations prepared for the Senate. Tax treaties and committee reports are located in part II.
  • International Bureau of Fiscal Documentation (IBFD)
    
  • Checkpoint (in the International Practice Area, under Primary Source Materials - Tax Treaties - U.S. Tax Treaties).
    
  • CCH Tax Treaties Reporter. KF6306 .C6 (library cancelled print updates in 2008).
  • CCH Tax Research Network (International Tax tab, U.S. Tax Treaties Reporter database).
    
  • Federal Tax Coordinator 2d. KF6285 .F4 1984. Volume 20 contains the full text of treaties negotiated by the U.S. and other countries involving income, gift and estate tax laws. Also available through Checkpoint.
  • Rufus von Thülen Rhoades & Marshall J. Langer, U.S. International Taxation and Tax Treaties (2001- ; loose-leaf for updating). KF6419 .R48. Includes the full text of U.S. tax treaties and agreements.
    • Also available electronically through Lexis: Rhoades & Langer U.S. International Taxation & Tax Treaties.
  • Westlaw: FTX-TREATIES.
  • TIARA Online. Not exclusive to the area of tax, TIARA provides full text of over 12,000 treaties and agreements, the earliest of which dates back to 1783. It also contains Senate Treaty documents from 96-1 through the current Congress, and U.S. Department of State documents from DOS 86-1 to the present.
• Legislative History Sources:
  • The legislative history of U.S. tax treaties includes Senate Foreign Relations Committee reports, Joint Committee on Taxation reports, and Treasury Department Technical Explanations.
  • Sources:
    • Lexis: Tax Analysts Worldwide Tax Treaties U.S. Legislative Histories.
    • Checkpoint (in the International Practice Area, under Primary Source Materials - Tax Treaties - U.S. Tax Treaties).
      
    • CCH Tax Treaties Reporter. KF6306 .C6 (Library cancelled updates in 2008).
    • CCH IntelliConnect Tax Research Network (International Tax tab, U.S. Tax Treaties Reporter database).
      
    • Legislative History of United States Tax Conventions. KF6306 .L43 1986r; (last updated in 2006). Provides access to legislative materials for those tax agreements to which the U.S. is a party, involving income, estate and gift tax. Documents included within the multi-volume set are, treaty status tables, Senate documents, Senate Foreign Relations Committee Hearings and news articles. This resource also includes the text of exchange agreements.
    • IRS Web Site Treasury Department Technical Explanations only.
    • Internal Revenue Bulletin. KF6301 .A1; issues from 1996 on also available electronically on the IRS home page. Includes Executive Reports and Treasury Department technical explanations prepared for the Senate. When available, tax treaties and committee reports are located in part II.
    • Cumulative Bulletin. KF6301 .A1. Includes Executive Reports and Treasury Department technical explanations prepared for the Senate. Tax treaties and committee reports are located in part II.

3. Non-U.S. Treaties.

Non-U.S. tax treaties are tax treaties between two or more countries that do not include the United States.

• Sources:
  • Lexis: Treaties & International Agreements.
    This area of Lexis contains many tax treaty databases, broken down by topic (i.e., there are separate databases for income tax treaties, estate tax treaties, mutual assistance treaties, etc.). Browse for the subject matter that interests you.
  • International Tax Treaties of All Nations. K4473 .A1 .I5. No longer updated in this library (last updated in 1997); for later treaties, see TIARA Online, listed below.
  • TIARA Online. Although not exclusive to the area of tax, TIARA provides full text of over 12,000 treaties and agreements, the earliest of which dates back to 1783.
  • International Bureau of Fiscal Documentation (IBFD)
    
  • International Bureau of Fiscal Documentation Loose-leaf Services 
    • These services include tax treaties along with other materials. The Library cancelled print updates in 2008, so it is recommended that the IBFD database be consulted first. There are separate services for each region:
      • African Tax Systems. KQC916 .I5 1970. (library cancelled updates in 2008).
        
      • Supplementary Service to European Taxation. KJC7101.3 .E97.
      • Taxation in Latin America. KG930 .T29 1987. (1987 -- 2008, library cancelled subscription)
        
      • Taxes and Investment in Asia and the Pacific. K4460.4 .I57 1978. (1978 -- 2008, library cancelled subscription).
        
      • Taxes and Investment in the Middle East. KMC916 .T39 1977. (1977--2008, library cancelled subscription).
        
  • United Nations Treaty Series. KZ172 .T74. Provides the full text of all treaties (including non-tax treaties) registered with Secretary-General of the United Nations. Coverage: 1946 to present.
    • Also available electronically through the United Nations Treaty Collection.
      

4. Treaty Status Information.

The database Tax Analysts Worldwide Tax Treaties In Force (Lexis: Tax Analysts Worldwide Tax Treaties In Force) contains only tax treaties that are currently in force.

For more information about finding the status of a treaty (e.g., is it ratified? is it perfected?) see the Library's Treaty Research Guide.

FOREIGN LAW

Foreign tax legislation is among the easiest foreign legislation to locate in English translation. When exact English translations are unavailable, summaries often are available. This section lists sources of foreign tax legislation in English, and foreign tax law summaries. Foreign case law on taxation is more difficult to come by, but this section also lists taxation-specific sources of foreign case law that are available in the Georgetown Law Library.

1. Legislation.

• International Bureau of Fiscal Documentation (IBFD)
  
• Spitz & Clarke Offshore Service. K4464.5.A5 T3 1998. (Library cancelled subscription in 2005). This multivolume loose-leaf service provides commentary, legislation, and selected case law from 25 tax havens.
  
• World Legal Information Institute (WorldLII) WorldLII provides links to foreign legislation on all subjects from many countries, some in English translation.

2. Summaries & Explanations.

• International Bureau of Fiscal Documentation (IBFD)
  • This database provides summaries and explanations of foreign tax laws, along with other materials. 
• BNA Foreign Income Tax Management Portfolios. BNA publishes loose-leaf handbooks to the tax laws of many individual foreign countries.
  • Print: KF6297 .B952, portfolio nos. 950 to 999.
  • Lexis: BNA Tax Management Portfolios - Foreign Income Series.
  • Westlaw: TM-FOR
  • BNA Tax Management Portfolio Collection
    
  • Bloomberg Law
• Tax Havens of the World: This multi-volume service provides information on the tax treaties, incentives, exemptions, and reductions offered by more than 70 jurisdictions worldwide. It also discusses the infrastructure, business environment, and economic and political stability of each jurisdiction.
• • Print: K4464.5 .D5 1974.(1974- 2008; Library cancelled print subscription). 
  • Lexis: Tax Havens of the World
    
• The Library owns many texts on tax law in individual countries. To locate works on the tax law of a specific country, try a keyword search in GULLiver for taxation and [country name] (e.g., taxation and argentina).

3. Case Law.

Nations vary greatly in their publication and reliance on case law. Nevertheless, limited sources do exist for foreign case law on international taxation issues. The sources listed here are taxation-specific resources.

• Lexis: Tax Analysts Worldwide Tax Treaties Case Law. This database provides selected cases from approximately 50 foreign countries on the interpretation of tax treaties. Dates of coverage vary by country, but generally the database covers the period 1890 to the present.
• International Bureau of Fiscal Documentation (IBFD): has foreign case law interpreting tax treaties and tax decisions of the European Court of Justice
  
• International Tax Law Reports. K4459.52 .I5. (1999 - 2006; Library cancelled subscription).
• Spitz & Clarke Offshore Service. INTL K4464.5.A5 T3 1998. (2001 -- 2005; Library cancelled subscription). This multi-volume loose-leaf service provides selected case law from 25 tax havens.
  

ORGANIZATIONS

• Organisation for Economic Co-operation and Development (OECD) Creates model tax conventions and publishes tax guidelines for member nations. Also issues occasional reports on the state of taxation in member countries.
  • Taxation page.
  • OECD iLibrary Includes many reports and other documents not available on the OECD web site.
• United Nations Committee of Experts on International Cooperation in Tax Matters. Reviews and updates as necessary the United Nations Model Double Taxation Convention between Developed and Developing Countries and the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries.