Allison Christians (Northwestern) recently presented Tax Treaties for Investment and Aid to Sub-Saharan Africa: A Case Study at Brooklyn. Here is the abstract:

In the United States, increasing trade and investment in less-developed countries (LDCs) has become a preferred means of providing aid to such countries. Thus, a key component of United States foreign aid strategy is the elimination of barriers to trade and investment. Among such barriers is double taxation, which occurs when two countries assert taxing jurisdiction on the same income. Double taxation is principally addressed through a network of double tax treaties, most of which are bilateral. The United States has continuously expressed both a commitment to enter into tax treaties with LDCs and a general conviction that tax treaties, including those with LDCs, will increase trade and investment between the partner countries. However, there are currently no tax treaties between the United States and the LDCs of Sub-Saharan Africa. Drawing from the relevant literature, available data, and field work in Ghana, this article presents a case study to determine whether a tax treaty between Ghana and the United States could be expected to increase trade and investment between the two countries. The case study suggests that the expected benefits of such an agreement are likely of minimal significance to cross-border investment due to the pervasive spread of low income taxation across the globe and the narrow scope of tax treaties in providing tax relief. This article therefore concludes that expansion of the United States tax treaty network to encompass the LDCs in Sub-Saharan Africa is unlikely to increase trade and investment to this area of the world.