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WU Vienna Tax law


Reuven Avi-Yonah

Graduated summa cum laude from Hebrew University in 1983. In 1986, he received a PhD in history from Harvard University, followed by a JD magna cum laude from Harvard Law School in 1989. He is Irwin I. Cohn Professor of Law at the University of Michigan Law School and director of the International Tax LL.M. Program at this university. He has served as a consultant to the US Treasury and the OECD on tax competition issues, and has been a member of the Executive Committee of the New York State Bar Association Tax Section, as well as of the US Income Advisory Board. Since 2008, he is a fellow of the American Bar Foundation; since 2007, senior fellow at the Taxation Law and Policy Research Institute at Monash University. Since 2005, he is member of the steering group of the OECD International Network for Tax Research. He is the author of several books and numerous articles.

The past two decades have seen a dramatic increase in the number of countries adopting controlled foreign corporation rules (CFC rules). Despite a conceptual connection to the domestic ”tax shelter” problem, CFC rules tend to apply only in an international setting. Further, the manner in which these rules are implemented from country to country shows a lack of uniformity. These features raise serious questions as regards the interaction between CFC rules and tax treaties and EU law. The main objective of this course is to gain an understanding of the policy underlying CFC rules, particularly within a broader conceptual perspective. The course will explore from a comparative view the approaches that countries take in implementing CFC rules. It will also explore the core issues that CFC rules raise in the context of tax treaties and EU law.

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