Conflicts of Attribution of Income Involving Trusts under the OECD Model Convention: The Possible Impact of the OECD Partnership Report

Robert J. Danon

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Taxation and Legal Issues Conflict of Laws and Jurisdiction Corporate Taxation and Avoidance

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The present contribution summarizes certain ideas expressed in our doctoral thesis.For a more extensive analysis of the issues discussed in this article thus see Robert J.

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2017Controlled Foreign Corporations as Fiscally Transparent Entities. The Application of CFC Rules in Tax Treaties 2019International Taxation of Trust Income 2020The Interaction of Domestic Anti-Avoidance Rules with Tax Treaties in the Post-BEPS and Digitalized World 2015Switzerland in a Post-BEPS World

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