Zvi Daniel Altman
S.J.D. 2005
Dissertation
Breaking the Barriers of Convention: Towards a Multilateral Dispute Settlement Procedure for Resolving International Tax Disputes
Analysis of the current international dispute resolution system under tax treaties - based solely on negotiation between tax authorities - demonstrates that it is inefficient in resolving such conflicts and fails to achieve the ultimate purpose of tax treaties to remove barriers to international trade and investments. I contend that a multilateral institution applying a multi-stage process based on consultation, arbitration, and non-binding preliminary opinions would provide a better forum for such dispute settlement. I intend to support my conclusions by way of a cost benefit analysis based on alternative dispute resolution scholarship, institutionalist international relations theories, past experience, and empirical analysis of various international dispute settlement procedures.
Fields of Research and Supervisors
- International Income Tax Policy and the Settlement of International Tax Disputes, with Professor Alvin C. Warren, Harvard Law School, Overall Faculty Supervisor
- Dispute Resolution Policies and Methods in International Trade and Investment Treaties, with Professor Joel P. Trachtman, The Fletcher School, Tufts University
- International Relations Theories, Political Science Theories and the Settlement of International Economic Disputes, with Professor Beth A. Simmons, Department of Government, Graduate School of Arts and Sciences, Harvard University
Additional Research Interests
- Income Tax Policy
- Consumption Tax Policy
- Arbitration under Bilateral Investment Treaties
Education
- Harvard Law School, S.J.D. Candidate 2003-Present
- Harvard Law School, International Tax Program 2002-2003
- Bar-Ilan University, Israel, LL.M. 1999
- Bar-Ilan University, Israel, B.A. in Economics 1999 (joint degree)
- Bar-Ilan University, Israel, LL.B. 1999
Appointments and Fellowships
- Harvard Law School, 2004-2005, Graduate Program Fellow, LL.M. Advisor
- Harvard Law School, 2003-2004, Graduate Program Fellow, LL.M. Writers Workshop
- Harvard Law School, Spring 2004, Teaching Assistant, International Aspects of U.S. Federal Taxation, Assistant Professor Diane M. Ring
- Harvard Law School, Fall 2003, Teaching Assistant, U.S. Federal Income Taxation, Professor Alvin C. Warren
- Bar-Ilan University Faculty of Law, Israel, 1996-1999, Law Review Editorial Board
- Bar-Ilan University Faculty of Law, Israel, 1996-1997, Teaching Assistant, Tax Law
- Bar -Ilan University Faculty of Law, Israel, 1994-1996, Research Assistant, Tax, Contracts and Constitutional Law
Representative Publications
- Dispute Resolution Under Tax Treaties (IBFD 2005), Winner of the Mitchell B Carroll Prize awarded by the International Fiscal Association (IFA), Amsterdam 2006
- The Implications of the ECJ Athinaiki Decision on the Distribution of Dividends under the Israeli Law for the Encouragement of Capital Investments 16/4 Missim A-1 (2002)
- “Dividend Striping” Transactions Following Compaq and IES, 16/2 Missim A-5 (2002)
- Israel Strives to Boost Foreign Investment, 13 International Tax Review 40 (2002). See also 26 Tax Notes Int'l 176 (2002)
- Survey of Israeli Tax System, 24 Tax Notes Int'l 1017 (2001). See also 24 Tax Notes Int'l 921 (2001)
Additional Information
- Personal Resume
- Full List of Publications and Public Appearances
- Taxation at Harvard Law School
- Languages: English, Hebrew