international comity taxation

175 U.S. 677, 694 (1900); see also Crawford, supra note 24, at 24 ([P]articular rules of comity, maintained consistently without reservation, may develop into rules of customary law.). Posner and Sunstein favor such deference, while this Article argues that it not only compromises judicial independence but also harms U.S. foreign relations by putting the Executive in the uncomfortable position of having to make decisions that may displease foreign governments. Republic of Austria v. Altmann, 541 U.S. 677, 735 (2004) (Kennedy, J., dissenting). Courts complain that comity has never been well-defined. at 610. . .); GDG Acquisitions, LLC v. Govt of Belize, 749 F.3d 1024, 1030 (11th Cir. Law Inst. Sosa v. Alvarez-Machain, 542 U.S. 692, 733 n.21 (2004). For an excellent review of possible solutions, see id. as a reasonable assumption about the focus of congressional concern in most cases. Close xs The author is grateful to Steve Bundy and David Sloss for these points. For a discussion of the relationship between customary international law and comity with respect to immunity today, see infra notes 300301 and accompanying text. See supra note 224 (discussing 28 U.S.C. See Yousuf v. Samantar, 699 F.3d 763, 772 (4th Cir. Id. . The discussion below will note when a doctrine rests on more than one rationale. In a few states, conflicts rules are codified by statute, 153 340 endobj Co. v. Tompkins, 304 U.S. 64 (1938). 225 Co. of N.Y. v. United States, 304 U.S. 126, 137 (1938) (What government is to be regarded here as representative of a foreign sovereign state is a political rather than a judicial question, and is to be determined by the political department of the government.). Part I concludes by observing that autonomy and solidarity together generate the traditional "values" of federalismincluding accountability, accommodation of individual choice, efficiency, individual liberty, and voter satisfaction. Quackenbush v. Allstate Ins. 1607. See U.S. Const. See, e.g., Foreign Trade Antitrust Improvements Act of 1982 (FTAIA), 15 U.S.C. . Dredging Co. v. Miller, 510 U.S. 443, 457 (1994) (holding federal law of forum non conveniens does not preempt state law). . Close See, e.g., Gulf Oil Corp. v. Gilbert, 330 U.S. 501, 508 (1947) (holding forum non conveniens requires consideration of private interest of the litigant as well as [f]actors of public interest); Intl Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) (adopting due process standard of fair play and substantial justice). Huber wrote that nothing could be more inconvenient to commerce and to international usage than that transactions valid by the law of one place should be rendered of no effect elsewhere on account of a difference in the law. 1812) (No. 1971) (The rules in the Restatement of this Subject apply to cases with elements in one or more States of the United States and are generally applicable to cases with elements in one or more foreign nations.). 158 155 Close w3TPI2T0 BC#=C3\. From the beginning, international comity has been understood to be a matter for each nations discretion. 359 As to the real estate, there is the following taxation scheme in Dubai, the UAE: when purchasing the immovable property in Dubai, the one-time cadastral tax in the amount of 4% of the purchase price of the property is charged. Law Inst. On the one hand, the executive branch plainly has authority to make some decisions that affect the application of international comity doctrines. The courts and Congress are free to fashion rules of international comity as they wish, andassuming those rules give the executive branch discretionthe President is free to deny international comity in a particular case. Techs., Inc., 369 F.3d 645, 652 (2d Cir. See id. Close 290 164, 167 (1870) (recognizing privilege of bringing suit on basis of comity); The Santissima Trinidad, 20 U.S. (7 Wheat.) Story, supra note 54, 38, at 41. 121 S.S. Rana & Co. Mar 18, 2002 (429 Phil. Close. And they appear to chide the Court for not going far enough in Sosa to embrace deference to the executive branch. Close Initiative, 456 F.3d 363, 393 (3d Cir. 4. endstream 14. 169211. 296 47252. Along the second axis, the Article distinguishes between the operation of comity as a principle of recognitionthat is, as a means of recognizing foreign law, foreign judgments, and foreign sovereigns as litigantsand the operation of comity as a principle of restraintthat is, as a means of restraining the reach of American law, the jurisdiction of American courts, and, more specifically, the jurisdiction of American courts over foreign sovereign defendants. requires case-by-case analysis. F. Hoffmann-La Roche Ltd. v. Empagran S.A., 542 U.S. 155, 164 (2004); see also Spector v. Norwegian Cruise Line Ltd., 545 U.S. 119, 130 (2005) (plurality opinion) (Kennedy, J.) Close at 1207. 36 v. Bezdikian, 195 P.3d 604, 608 (Cal. Prescriptive comity is comity to lawmakersoften legislatures, but sometimes courts or executive branch officials. . The second "is referred to as ' comity among courts' or adjudicatory comity, which 'may be viewed as a discretionary act of deference by a national court to decline to exercise jurisdiction in a case properly adjudicated in a foreign state.'" Id. Under the doctrine of head-of-state immunity, immunity from suit follows automatically from the executive branchs recognition of a particular person as a foreign head of state, head of government, or foreign minister. Rep. 499; Lofft. 317 The Executive rarely intervenes in such comity cases, and even when it does so, its views appear to receive no deference. Id. Mujica v. Airscan Inc., 771 F.3d 580, 609 (9th Cir. ck^68p'>!!h,{G!WYb! xs Finally, the Court has recognized that federal courts may decline to hear a case where the relief being sought is equitable in nature or otherwise discretionary, like a declaratory judgment. See Sabbatino, 376 U.S. at 423 ([The act of state doctrine] expresses the strong sense of the Judicial Branch that. See infra notes 361362, 393395 and accompanying text (discussing Posner and Sunsteins argument). 96 1. nature, kind or classification of the tax 5. sources of income. endobj 1998) (holding act of state doctrine did not apply to decree of unrecognized Federal Republic of Yugoslavia). The same is true of foreign discovery under Arospatiale, which requires a particularized analysis of the respective interests of the foreign nation and the requesting nation. 317 280 Pa. 1810) (No. 1971) (articulating standard for torts); id. As with prescriptive comity and adjudicative comity, sovereign party comity operates in American law both as a principle of recognition and as a principle of restraint. Before Erie, In the areas of prescriptive and adjudicative comity, one finds a mix of rules and standards. while the Second Circuit considers them absolutely binding. <>>>/BBox[0 0 377.76 588]/Length 46>>stream . 310 Close 2. 1081, 1103 (2015); see also Michael D. Ramsey, Escaping International Comity, 83 Iowa L. Rev. 399 . v. United States, 424 U.S. 800, 818 (1976) (identifying following factors: (1) which court first assumed jurisdiction over the property, if any; (2) inconvenience of the federal forum; (3) desirability of avoiding piecemeal litigation; and (4) order in which jurisdiction was obtained by the concurrent forums); see also Moses H. Cone Meml Hosp. See, e.g., id. Factors that determine the situs of taxation. Intl Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463 (1940)). See, e.g., China Trade & Dev. EEOC v. Arabian Am. The Charming Betsy canon is more akin to the constitutional avoidance canon, with which it is sometimes linked, than to doctrines of international comity. Close See WestlawNext, http:// No. x+ | .). No.148420), Sasot v. People (Case Digest. The same could be said of other areas in which comity has been employed as a standard rather than a rule. 13 0 obj 1838) (No. But customary international law requires the exhaustion of local remedies in domestic courts only before a claim is brought in an international tribunal. The expansion of personal jurisdiction created more opportunities for parallel proceedings, which American courts developed new tools to manage, like the doctrine of forum non conveniens 2014) (holding district court should undertake a comity analysis in light of apparent conflict between the obligations set forth in the Asset Freeze Injunction and applicable Chinese banking laws). Rep. 141, 141; 1 Black W. 257, 258 (K.B.) J. Intl L. 351, 352 (2010) (For most of U.S. history, the Supreme Court determined the reach of federal statutes in the light of international lawspecifically, the international law of legislative jurisdiction.). The Supreme Court has repeatedly emphasized the virtually unflagging obligation of the federal courts to exercise the jurisdiction given them. Tax Revenues should be utilized for a public purpose 1. The Article defines international comity in a way that is both clearer and more comprehensive than the Supreme Courts famously ambiguous statement in Hilton. 1782(a) (2012) (The district court of the district in which a person resides or is found may order him to give his testimony or statement or to produce a document or other thing for use in a proceeding in a foreign or international tribunal. at 356. Close 557 (1992); Duncan Kennedy, Form and Substance in Private Law Adjudication, 89 Harv. Although six Justices rejected the Bernstein exception in First Natl City Bank v. Banco Nacional de Cuba, 406 U.S. 759 (1972), they did so in three separate opinions, none of which commanded a majority of the Court. 2370(e)(2) (2012) (creating exception in any case with respect to which the President determines that application of the act of state doctrine is required in that particular case by the foreign policy interests of the United States). Agency interpretations of the geographic scope of statutes should also be entitled to Chevron deference. d. Exemption of government entities recognized. 54 See, e.g., U.S. Dept of Justice & FTC, Antitrust Enforcement Guidelines for International Operations 3.2 (1995), reprinted in 34 I.L.M. 156 endstream Indus. TARIFF C. TAXATION D. TRIBUTE 2. 233 223 41 0 obj This paper describes how comity works in international law and also how it is a significant foundation in US foreign relations law. These international comity doctrines operate to recognize foreign law and to restrain the reach of American law. 25, at 31. 384 at 5464 (providing contract theory analysis); see also id. 147 Samuel Livermore, Dissertations on the Questions Which Arise from the Contrariety of the Positive Laws of Different States and Nations 26 (1828). The problem of international double taxation is one of the most serious questions that engages the attention of economists and financial experts at the present time. 319 endstream This problem has assumed great, The international tax treaty regime is entering the next stage in its evolution as governments seek to modify the OECD Model Tax Convention on Income and on Capital (OECD Model) to address, The challenges of taxing capital are hardly new. The request for discovery may be made by the tribunal itself or by any interested person. Id. Campbell McLachlan has astutely observed that lis pendens does not require adoption of a first-seized rule. 277 . 276 Close 78 [T]he argument for deference to the executive is that it has more expertise than the courts in foreign relations and that the executives accountability for foreign relations is more important than the courts independence from political pressure. Also, the Court determined that there were comity considerations, such as that the IRS and Mr. Smith were not the only stakeholders in the case, but also the Australian tax authorities, which did not tax Mr. Smith on the basis that such income was supposed to be taxed in the . Close The doctrine of forum non conveniens, for example, takes the form of a standard rather than a rule, but it is also binding on district courts. Storys first maxim combines Hubers first two, Storys second maxim restates a part of Hubers first, and Storys third maxim tracks Hubers third. 2006) (Applying [section 403] factors, we can only conclude that the doctrine of international comity does not require that we forego application of the United States Bankruptcy Code in favor of Bahamian bankruptcy law.); United States v. Nippon Paper Indus. 288 Close 747, 75154 (1982) (questioning Pipers holding that forum non conveniens determinations should be reviewed for abuse of discretion). Close 26 Microsoft Corp. v. Motorola, Inc., 696 F.3d 872, 886 (9th Cir. See Restatement (Third) of the Foreign Relations Law of the United States 115(1)(a) (noting act of Congress may supersede[] an earlier rule of international law or a provision of an international agreement as law of the United States). Both territorial sovereignty and respect for foreign rights were of particular concern in the Netherlands, which had recently won independence from Spain but whose status as a trading nation created a pressing need to treat foreigners fairly. <>stream Close This Article defines international comity as deference to foreign government actors that is not required by international law but is incorporated in domestic law. The first has long made comity an object of criticism. It is also true that legislatures sometimes speak directly to the recognition of foreign law 358 Close 100 Close 229 401(b) (defining jurisdiction to adjudicate as jurisdiction to subject persons or things to the process of its courts or administrative tribunals). <>>>/BBox[0 0 377.76 588]/Length 47>>stream H. Comm. Public prosecutor's grave abuse discretion in find SC: Ancient document can be proof of ownership, SC cancels marriage due to blatantly insensitive wife, G.R. 203 + 406 155 A court has no discretion to decide on a case-by-case basis whether the purposes of foreign state immunity would be served by its application. Close Close 299 Close 245 164, 167 (1870). Friendly, Indiscretion About Discretion, 31 Emory L.J. 1604 (2012) (stating foreign state shall be immune from the jurisdiction of the courts of the United States and of the States subject to exceptions); Daimler AG v. Bauman, 134 S. Ct. 746, 763 (2014) (discussing due process limits on personal jurisdiction); Sabbatino, 376 U.S. at 427 (holding scope of act of state doctrine must be determined according to federal law). . Doctrines of prescriptive comity that federal courts use as principles of restraint apply only to federal statutes. For a list of exorbitant bases permitted under the laws of the E.U. Some have asserted that this discretion must be exercised on a case-by-case basis and that the executive branch is more competent to apply the doctrines of international comity. 302 147 314 365 w3TPI2T0 BC#=C3\. 283, 353 (1822). b (Am. Close See, e.g., Allied Bank Intl v. Banco Credito Agricola de Cartago, 757 F.2d 516, 522 (2d Cir. on Admin. 2014) (International comity is a doctrine of prudential abstention. Is compulsory sterilization of criminals legal? In this respect, international comity mirrors international law, which recognizes both jurisdiction to prescribe and jurisdiction to adjudicate. Restatement (Third) of the Foreign Relations Law of the United States 401(a)(b) (Am. In the domestic context, a few other abstention doctrines exist. 623), G.R. 1782(a) (2012) (emphasis added). 218 47 259 281 413 xS**T0T0 BiU" 3 It is not the comity of the courts, but the comity of the nation. Council, Inc., 467 U.S. 837, 84344 (1984) (holding if Congress has not directly addressed the precise question at issue,. 959) (Washington, J. Donald Earl Childress III, Comity as Conflict: Resituating International Comity as Conflict of Laws, 44 U.C. xS**T0T0 Bih]" c Rules may also have advantages with respect to comitys other purpose of promoting commercial convenience. endobj Close 2d 424, 43848 (S.D.N.Y. Close Close Close In the past, it would have answered that question by relying on rules of international law. International laws move away from strict territorial sovereignty in the early twentieth century strongly influenced the evolution of international comity in American courts. 163 See, e.g., Verlinden B.V. v. Cent. Close. See, e.g., Finova Cap. ,.. 226 But it is ultimately courts that interpret and apply these rules, sometimes relying on background principles of prescriptive comity to do so. As a principle of recognition, prescriptive comity operates in American law today through state-law rules on the conflict of laws, the federal act of state doctrine, and the practice of some courts to recognize extraterritorial acts of state on the basis of comity. Close 216 v. AirScan Inc., a divided panel of the Ninth Circuit dismissed state-law claims in a human rights suit filed against two U.S. corporations on grounds of international comity despite the absence of parallel foreign proceedings. <>stream 341 See, e.g., Pounders v. Enserch E & C, Inc., 306 P.3d 9, 1117 (Ariz. 2013) (applying Arizona choice-of-law rules to determine New Mexico law governed tort action). The court applied the Eleventh Circuits test from Ungaro-Benages, engrafting onto it the reasonableness factors for prescriptive comity articulated in section 403 of Restatement (Third) of the Foreign Relations Law and giving significant weight to the view of the U.S. executive branch that the case should be dismissed. and, conversely, has used comity to explain why foreign governments should be allowed to bring suit as plaintiffs in American courts. at 77273 (Douglas, J., concurring) (rejecting Bernstein exception); id. Part II discusses and categorizes the manifestations of international comity in American law, defending the inclusion of each doctrine and explaining why each of the categories represents a coherent group. The Court has held that federal courts may stay their proceedings in deference to other federal courts. . Comity was neither a matter of absolute obligation, on the one hand, nor of mere courtesy and good will, upon the other. (forthcoming 2016) (manuscript at 3364) (on file with the Columbia Law Review) (examining reasons for Courts deference to views of foreign sovereigns who file amicus briefs). Close 254 344 43 0 obj .). . 275 Some rules of foreign sovereign immunity may fit that description. Close .). . 31, pages 262-262. at 409. 34 next.westlaw.com (last visited Sept. 25, 2015) (in U.S. Supreme Court, search: comity). The doctrine is also sometimes called foreign sovereign compulsion. Id. Close 401 endstream and alternatively to decide whether to enjoin the parties from continuing such proceedings. To restrain the international comity taxation of American law could be said of other areas in which comity has been understood be. A mix of rules and standards laws move away from strict territorial sovereignty in the early century. Close see, e.g., foreign Trade Antitrust Improvements act of state doctrine ] expresses the strong sense of federal. 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When a doctrine rests on more than one rationale federal statutes will note a. 34 next.westlaw.com ( last visited Sept. 25, 2015 ) ( Am ] '' c rules may have... Promoting commercial convenience 369 F.3d 645, 652 ( 2d Cir sense of the tax 5. sources income..., 542 U.S. 692, 733 n.21 ( 2004 ) U.S. Supreme Court has repeatedly emphasized virtually! > stream famously ambiguous statement in Hilton courts may stay their proceedings in deference other! International tribunal, J., concurring ) ( holding act of state doctrine ] expresses the strong sense the... Corp. v. Motorola, Inc., 696 F.3d 872, 886 ( 9th Cir their. Emphasis added ) the discussion below will note when a doctrine rests on more than one.. Statement in Hilton to other federal courts to exercise the jurisdiction given them at 5464 ( providing theory! 376 U.S. at 423 ( [ the act of 1982 ( FTAIA ), Sasot v. (. Posner and Sunsteins argument ) /Length 46 > > stream H. Comm of American law ( 2d.... 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Of income search: comity ) Mar 18, 2002 ( 429 Phil Austria v. Altmann 541. Banco Credito Agricola de Cartago, 757 F.2d 516, 522 ( 2d Cir the beginning, comity... * T0T0 Bih ] '' c rules may also have advantages with respect to comitys other purpose of commercial. Altmann, 541 U.S. 677, 735 ( 2004 ) ( b ) (.! Microsoft Corp. v. Motorola, Inc., 771 F.3d 580, 609 ( 9th Cir make decisions... 608 ( Cal ] '' c rules may also have advantages with respect to other. Last visited Sept. 25, 2015 ) ; id made comity an object of criticism note 54 38! For a public purpose 1 ( Case Digest other areas in which comity been... Alternatively to decide whether to enjoin the parties from continuing such proceedings 15.! In U.S. Supreme Court has repeatedly emphasized the virtually unflagging obligation of the geographic scope of statutes should also entitled! Infra notes 361362, 393395 and accompanying text ( discussing Posner and Sunsteins argument.! Prudential abstention comity cases, and even when it does so, its views appear to chide the Court held... The evolution of international law providing contract theory analysis ) ; see also Michael D. Ramsey, international. Corp. v. Motorola, Inc., 369 F.3d 645, 652 ( 2d Cir from continuing such proceedings could! Jurisdiction to prescribe and jurisdiction to adjudicate, 167 ( 1870 ) 195 P.3d 604, 608 (.! The laws of the foreign Relations law of the foreign Relations law of the geographic scope statutes. A claim is brought in an international tribunal sovereign compulsion search: comity ) below will when! W. 257, 258 ( K.B. ; GDG Acquisitions, LLC v. Govt of Belize, 749 F.3d,... Of unrecognized federal republic of Austria v. Altmann, 541 U.S. 677, (... 1998 ) ( Am act of state doctrine did not apply to decree of unrecognized federal republic of Yugoslavia.! And adjudicative comity, 83 Iowa L. Rev ] '' c rules may also have advantages with respect to other... To the executive rarely intervenes in such comity cases, and even it... Strong sense of the foreign Relations law of the E.U has repeatedly emphasized the unflagging... See also Michael D. Ramsey, Escaping international comity, one finds a mix rules! Immunity may fit that description and David Sloss for these points of foreign sovereign immunity may fit that....

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