UF Law Scholarship Repository

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Understanding the OECD Model Tax Convention: The Lesson of History
John F. Avery Jones

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The Tax Hedging Rules Revisited
Dr. Yoram Keinan

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Accessions to Wealth, Realization of Gross Income, and Dominion and Control: Applying the "Claim of Right Doctrine" to Found Objects, Including Record-Setting Baseballs
Joseph M. Dodge

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Mandatory Arbitration of International Tax Disputes: A Solution in Search of a Problem
Ehab Farah

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Considering "Citizenship Taxation": In Defense of FATCA
Young Ran (Christine) Kim

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Tax Aspects of REMIC Residual Interests
Kirk Van Brunt

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U.S. Federal Income Taxation of U.S. Branches of Foreign Banks: Selected Issues and Perspectives
Yaron Z. Reich

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The U.S. and Chile Tax Treaty and its Impact on Foreign Direct Investment
Hugo Hurtado

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Back to the Future Interest: The Origin and Questionable Legal Basis of the Use of Crummey Withdrawal Powers to Obtain the Federal Gift Tax Annual Exclusion
Bradley E.S. Fogel

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Tax Fairness by Convention: A Defense of Horizontal Equity
Ira K. Lindsay