Mark Allison Moderates Panel on Foreign Tax Judgments at ABA 2020 Midyear Meeting

This panel will explore the means and methods by which foreign governments come onshore to try and collect their tax determinations and judgments in the United States, including through the use of bilateral tax treaties and US judicial proceedings. The panel will also identify the defenses and limitations to such actions, including through jurisdictional limits such as the Revenue Rule a longstanding principle of the U.S. and international law that prohibits one sovereign from using courts of another sovereign to enforce its revenue laws.