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Abstract

There is a growing trend in the United States for the adoption of the VCLT in analyzing international tax treaties.1 This trend is positive and should be continued. By looking at how the VCLT could have been applied to the tax treaty interpretation in dispute in Xerox Corp. v. U.S., I assert both that it should be seen as a legitimate source of international tax law and that it should continue to be used moving into the future.

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