Text, Intent and Taxation in the United States, the United Kingdom and France

Document Type

Article

Publication Date

9-30-2020

Editor(s)

Nigar Hashimzade and Yuliya Epifantseva

ISBN

9780367656164

Publisher

Routledge

Language

en-US

Abstract

Along with an impressive evolutionary cross-comparison of the anti-avoidance approaches in the United States, the UK and France, this chapter provides several general insights that echo the previous parts of the Companion. In particular, it explores the similarities and divergence of the doctrines developed by courts when attempting to strike the balance between preserving the rule of law and giving the necessary tools to tax authorities to curb tax avoidance. This comparison is especially interesting in light of the different traditions of legislative-judicial interactions and doctrinal development in common law jurisdictions of the United States and the UK vis-à-vis the civil law system in France.

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