Zvi Daniel Altman

[candidate photo]

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.

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