Treaty Override by Administrative Regulation: The Multiparty Financing Regulations

Authors

• Richard L. Doernberg, Emory University School of LawFollow

Abstract

This article focuses on whether the Treasury is authorized by the Constitution and by Congress to override U.S. treaty commitments. The article also analyzes the effect of an administrative override, if permissible, under treaties ratified after the enactment of section7701(l).

Recommended Citation

Richard L. Doernberg, Treaty Override by Administrative Regulation: The Multiparty Financing Regulations, 2 Fla. Tax Rev. (1995).
Available at: https://scholarship.law.ufl.edu/ftr/vol2/iss1/11