Abstract
The first treaty between the United States and Mexico for the avoidance of double taxation (Treaty) entered into force on January 1, 1994. The Treaty represents a significant milestone in the economic relations between the two countries, especially in light of the historic North American Free Trade Agreement (NAFTA). The Treaty complements NAFTA and will improve the investment climate in both countries, building on an already dynamic economic partnership between the United States and Mexico.
The purpose of this article is to analyze the Treaty in the context of model bilateral tax treaties and other recent U.S. tax treaties, with an emphasis on U.S. companies and individuals doing or contemplating doing business in Mexico. Part II provides an overview of the purpose and legal status of bilateral tax treaties. Part III discusses the scope of the Treaty and the requirements for its application. The Treaty’s substantive income taxation rules are analyzed in part IV. Part IV also outlines special provisions, such as relief from double taxation, nondiscrimination, exchange of information, and the procedures for dispute resolution. Finally, part V provides a brief conclusion.
Recommended Citation
Smith, Eric J.
(1993)
"The U.S.-Mexico Tax Treaty,"
Florida Journal of International Law: Vol. 8:
Iss.
1, Article 4.
Available at:
https://scholarship.law.ufl.edu/fjil/vol8/iss1/4