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Avi-Yonah: The U.S. Should Terminate Its Tax Treaty With Russia

Reuven Avi-Yonah (Michigan; Google Scholar), The United States Should Terminate Its Tax Treaty With Russia, 174 Tax Notes Fed. 1561 (Mar. 14, 2022):

Tax Notes Federal (2020)I read with interest Marty Sullivan’s recent article arguing against terminating the U.S. tax treaty with Russia, and I respectfully disagree. (Martin A. Sullivan, “Should the United States Terminate Its Tax Treaty With Russia?” Tax Notes Federal, Mar. 7, 2022, p. 1327.) …

Sullivan is skeptical of using tax for nontax purposes. I would argue that the corporate tax has always been used primarily as a regulatory device, and there is no difference between using it for foreign policy goals than using it for other non-revenue-raising goals like discouraging pollution or encouraging green investments.

Given the seriousness of the crisis, the United States should consider all means to hurt the Russian regime, including terminating the tax treaty.


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