Do all international tax lawyers and accountants only provide services in relation to off-shore trust work?
Well I guess this depends upon how you define the term “international tax lawyer”. My definition of international tax lawyer is a lawyer who provides services in respection of international taxation – therefore what constitutes an international tax lawyer depends on how you define “international tax”. In defining the concept of international tax, I cant go past Michael Graetz (probably the foremost expert on international tax policy) who said that the ‘basic task of international tax rules is to resolve the competing claims of residence and source nations’. [1] Accordingly, international tax laws are those rules that delineate a country’s taxation of cross jurisdictional income. This includes transfer pricing provisions, thin capitalisation issues, tax residency questions, income source etc. Accordingly, I consider an international tax lawyer to be a lawyer who regularly gives advice on such rules. Whether that lawyer is an expert in another country’s tax laws is not relevant. Just as
