The history of international tax treaties from the US perspective (18th October 2023)

Authors

Reuven Avi-Yonah
University of Michigan image/svg+xml

Synopsis

The first tax treaty of the United States, signed with France in 1932 and
ratified in 1935, reflects the 1928 League of Nations model, with significant
differences due mainly to the different tax structures of the two countries: a
“global” jurisdiction for the United States and a “territorial” one for France.
This treaty represents an important precedent for subsequent agreements between
countries with different tax regimes and a key step in the development of
the modern international tax treaties system.

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Published

September 26, 2025