Congressional Unilaterla Tax Treaty Overrides: The "Latter in Time Doctrine" is Out of Time!

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Professor Mark J. Wolff


The current form of globalization has resulted in greater global economic integration and liberalization, political openness, and cultural and social acceptance. As the world economy continues to weaken national economic orders, and as nations become more dependent upon international trade, good relations between nations may provide greater global wealth and political stability. Global integration requires a “cooperative multilateralist” approach, encouraging international alliances, partnerships and institutions. The current global shift, however, finds the United States in a period of protectionism. As a result of 9/11, the United States has begun a strategy of preemption, one triggered at creating measures aimed at preventing substantial casualties to the U.S., whether military or economic. The actions taken in furtherance of this strategy, such as the invasion of Iraq without the consent of the Security Council, altered the perception of the United States around the world. Furthermore, these actions were in direct contradiction of Secretary of State Condoleezza Rice’s pledge to “support and uphold the system of international rules and treaties that allow us to take advantage of our freedom.”

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