Article 13 of the OECD Model tax treaty allows a source country to retain taxing rights on capital gains realized by non-residents on the sale of real (immovable) property in the source country. Recently, it has been modified to incorporate a further rule that has long been a feature of the UN...

Firms that lobbied for the tax holiday for repatriations provided under the American Jobs Creations Act of 2004 were the largest beneficiaries of the provision. They repatriated an average of over $4 billion under the Jobs Act. Although firms that lobbied for the tax holiday repatriated large...