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Treaty between Australia and United States – US tax debts not enforceable in

18 June 2007

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Treaty Development

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Australia-United States

Australia The New South Wales Supreme Court on 18 April 2007 handed down a decision in Jamieson v Commissioner for Internal Revenue [2007] NSWSC 324, in which the court decided that orders of the United States Tax Court are not enforceable in Australia. Relevant to the case, the Commissioner of Internal Revenue of the Internal Revenue Service of the United States obtained a judgement from the United States Tax Court against the estate of the plaintiff, who is the executrix of the estate. The Court accepted that Article 27 of the OECD Model Tax Convention allows claims on behalf of...