international comity taxation

• kathy garver clearcaptions commercial
• December 11, 2022

Res. Second, Hubers final maxim expressly permitted discretion by the sovereign, which could deny the effect of foreign law to the extent necessary to protect itself and its subjects. But the predominant manifestation of prescriptive comity as a principle of restraint in American law today is the presumption against extraterritoriality, which operates as a rule. Court for S. Dist. Rep. 99, 78 (Feb. 3) (discussing state immunity for military activities during armed conflict); Arrest Warrant of 11 April 2000 (Dem. to limit the federal-common-law cause of action for human rights violations under the Alien Tort Statute (ATS), emphasizing that the presumption serves to protect against unintended clashes between our laws and those of other nations which could result in international discord.. 213, 254 (acknowledging Courts holding in Samantar that federal common law now controls these issues). 95 U.S. 714, 722 (1877) (holding no state can extend its process beyond that territory so as to subject either persons or property to its decisions). See 28 U.S.C. 2007) (equating deference suggested in Sosa with prudential justiciability doctrine known as the political question doctrine (internal quotation marks omitted)). 266 . See, e.g., Republic of the Philippines v. Pimentel, 553 U.S. 851, 866 (2008) (Giving full effect to sovereign immunity promotes the comity interests that have contributed to the development of the immunity doctrine.); Dole Food Co. v. Patrickson, 538 U.S. 468, 479 (2003) (Foreign sovereign immunity . and (2) it reflects the assumption that Congress is primarily concerned with domestic conditions. The scope of taxation is regarded as comprehensive, plenary, unlimited and supreme. It is based on the assumption that Congress is primarily concerned with domestic conditions.); see also William S. Dodge, Understanding the Presumption Against Extraterritoriality, 16 Berkeley J. Intl L. 85, 11719 (1998) (discussing domestic conditions rationale). Close 285 Lower courts have continued to rely on comity to enforce foreign acts of state not covered by the doctrine because they were not fully performed within the foreign states own territory. . 40 168 See 28 U.S.C. Most problematic are international comity doctrines that would allow the Executive to dictate the outcome of particular cases, like the Bernstein exception to the act of state doctrine or the authority that the executive branch currently claims to make binding determinations with respect to the conduct-based immunity of foreign officials. 379 1, 2014) (noting no Uniform Act requires reciprocity for recognition of foreign judgment, although six states have added reciprocity as condition for recognition). The jurisdiction of the nation within its own territory is necessarily exclusive and absolute, Marshall wrote. . See Bank of Augusta v. Earle, 38 U.S. (13 Pet.) Law Inst., Preliminary Draft No. (quoting Intl Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)). 292 The law of nations at the time was said to consist of four categories: (1) the necessary; (2) the voluntary; (3) the customary; and (4) the conventional. 113 372 Choong Yong, 837 F.2d 33, 37 (2d Cir. 1994). Close, In the area of prescriptive comity, one finds both rules and standards. 220 should be exempt from the jurisdiction of the country.). Although the Third Restatement took the position that such interest balancing was required by customary international law, See id. See, e.g., Calamita, supra note 37, at 637 (noting adjudicatory comity serves as the founding principle for the courts acceptance of [forum non conveniens]); Slaughter, A Global Community of Courts, supra note 37, at 205 (As courts grapple with issues such as forum selection clauses, forum non conveniens motions, and parallel suits, they are developing a more nuanced conception of judicial comity.). Close (2) All persons within the limits of a government, whether they live there permanently or temporarily, are deemed to be subjects thereof. 264 In the Arospatiale case, for example, the Supreme Court had to decide whether to require first resort to the Hague Evidence Convention for the gathering of evidence abroad. In more recent times, the Supreme Court has consistently characterized foreign sovereign immunity as a matter of grace and comity on the part of the United States. Close, On the restraint side of the ledger, some courts applying section 403 of the Restatement (Third) of Foreign Relations Law have determined the geographic scope of U.S. statutes on a case-by-case basis. The exception to this trend has been adjudicative jurisdiction, where courts seem to have moved away from respect for sovereignty It. WebInternational comity 3. 7814) (Washington, J.) The lower courts approach to extraterritorial acts of state is more of a standard, calling for an evaluation of the foreign acts consistency with U.S. policy in each case. 1987) (Where fairly possible, a United States statute is to be construed so as not to conflict with international law or with an international agreement of the United States.). 95 267 72 16 18 It catalogues and categorizes the uses of international comity in American law, based on a reading of all the U.S. Supreme Court opinions mentioning comity, as well as a number of lower court decisions. See Restatement (Fourth) of the Foreign Relations Law of the United States: Jurisdiction 222 cmt. Despite its slippery definition of comity, Second, the shift from private to public obscured the basis in comity of certain doctrines that protect private interests, like forum non conveniens. Microsoft Corp. v. Motorola, Inc., 696 F.3d 872, 886 (9th Cir. Some doctrines, like forum non conveniens, may properly take the form of standards rather than rules. See supra note 224 (discussing 28 U.S.C. . 101, 102 (1993) (proposing single omnibus comity inquiry conducted as early as possible in the litigation process). 1971) (rejecting reciprocity requirement for conflict of laws). 178 300 Close Close International law binds the United States on the international plane, 229 Close Bank N.Y. Tr. 294 21) (The rule that local remedies must be exhausted before international proceedings may be instituted is a well-established rule of customary international law. Close 1109, 1169 (2014) (If a policy of judgments reciprocity is unlikely to persuade the nations that currently refuse to enforce U.S. judgments to change their practiceas seems to be the casethen the answer to the question of whether to adopt such a policy is easy.). Close 130 As a general matter, [d]ue process limits on the States adjudicative authority principally protect the liberty of the nonresident defendant. (rejecting idea of discretionary authority to avoid parallel proceedings and stating no federal court can escape from its duty, in any case, which congress has confided to its jurisdiction). . 30 Def. The literature is voluminous. 1517 (2012) (authorizing order recognizing foreign bankruptcy proceeding); see also In re Vitro S.A.B. The Court has recognized exceptions for countries at war with the United States or not recognized by the United States. 110 See 28 U.S.C. 1945) (Hand, J.) at 227 ([J]udgments rendered in France, or in any other foreign country, by the laws of which our own judgments are reviewable upon the merits, are not entitled to full credit and conclusive effect when sued upon in this country. See W.S. Speaking only of acts, this definition leaves out foreign sovereign immunity and a foreign states privilege of bringing suit in U.S. courts, both of which the Supreme Court had recognized as manifestations of international comity well before Hilton was decided. See supra notes 257258 and accompanying text (discussing Ninth Circuits decision in Mujica). 299 665, 678 (La. 2d 451, 458 (S.D.N.Y. On the same day, the Court held that a Canadian judgment was entitled to enforcement because Canada gave full effect to U.S. judgments. . Cf. 1080, 1102 (1995) (In enforcing the antitrust laws, the Agencies consider international comity.); see also The Paquete Habana, 175 U.S. 677, 69394 (1900) (characterizing Executives decision not to seize coastal fishing vessels as prizes of war, prior to its evolution into rule of customary international law, as exercise of comity); United States v. Rauscher, 119 U.S. 407, 41112 (1886) (noting decision to deliver fugitive to foreign government in absence of extradition treaty was act of comity). Id. 47 Close. 224 In Holman v. Johnson, he added: The doctrine Huberus lays down, is founded in good sense, and upon general principles of justice. 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.). To permit the validity of the acts of one sovereign State to be reexamined and perhaps condemned by the courts of another would very certainly imperil the amicable relations between governments and vex the peace of nations. at 356. Once that focus has been established and the territorial reach of a provision determined, however, the geographic scope of the provision remains the same in each case. 91 37 321 Whether a doctrine takes the form of a rule or a standard is a separate question from whether that doctrine binds the court as a rule of law. 298 WebA fundamental rule in taxation is that the property of one country may not be taxed by another country. This known as [RPCPA} a. But reviewing the doctrines of international comity shows that many of them are more rule-like than standard-like. Donald Trump pleaded not guilty Tuesday to 34 felony counts of falsifying business records related to his alleged role in all nations had consented to treat the foreign sovereign himself, his foreign minister, and his military forces as immune from arrest or detention within their territories. See Colo. River Water Conservation Dist. 136 42 U.S.C. depends upon what our greatest jurists have been content to call the comity of nations). Third, this Article uses its categorization of international comity doctrines to challenge two enduring myths about comity: (1) that comity must be governed by standards rather than rules; and (2) that comity determinations are best left to the executive branch. 46 14mc00190 (JSR), 2014 WL 3893953, at *1 (S.D.N.Y. Finally, this categorization does not include the Charming Betsy canon of avoiding violations of international law, 363 American courts generally apply the same choice-of-law rules in interstate and international cases. 1987) (States. Mfg. Law Inst., Tentative Draft No. v. Bezdikian, 195 P.3d 604, 608 (Cal. .). 1987). Inspired by a footnote in the Supreme Courts Sosa decision, Public interests found expression only as a justification for not extending comity to foreign laws, because under Hubers third maxim, one nation would enforce the laws of another only insofar as they do not cause prejudice to the power or rights of such government or of its subjects. Republic of Austria v. Altmann, 541 U.S. 677, 735 (2004) (Kennedy, J., dissenting). (referring to international comity to limit interference with internal affairs of foreign-flag ship); Sosa v. Alvarez-Machain, 542 U.S. 692, 761 (2004) (Breyer, J., concurring in part and concurring in the judgment) (referring to notions of comity that lead each nation to respect the sovereign rights of other nations by limiting the reach of its laws and their enforcement). J. Transnatl L. 819, 835 (2011). 244 These different ways of exercising adjudicative comity can best be viewed as parts of a larger whole. 2005) (The doctrine has never been well-defined, leading one scholar to pronounce it an amorphous never-never land whose borders are marked by fuzzy lines of politics, courtesy, and good faith. (quoting Harold G. Maier, Extraterritorial Jurisdiction at a Crossroads: An Intersection Between Public and Private International Law, 76 Am. Federal courts also exercise adjudicative comity as a principle of recognition when they assist foreign courts with the discovery of evidence in the United States. Wuerth, supra note 383, at 953. Today, American courts also use international comity to restrain the reach of domestic law. 186 that the foreign relations interests of the United States. 270 86 F. Hoffmann-La Roche Ltd. v. Empagran S.A., 542 U.S. 155, 164 (2004). Close 364 It has three goals: (1) to offer a better definition of international comity and a framework for analyzing its manifestations in American law; (2) to explain the relationship between international comity and international law; and (3) to challenge the myths that international comity doctrines must take the form of standards rather than rules and that international comity determinations should be left to the executive branch. The State can enforce contributions upon its citizens in the form of taxes even without a constitutional provisions authorized it. 1812) (No. 339 Close 190 Close 1319, 1320 (C.C.D. 7 2008) (en banc) (plurality opinion) (McKeown, J. A panel of the Ninth Circuit later applied the doctrine to an expropriation claim brought under the FSIA, though that decision was later vacated when the case was reheard en banc. . . Part IV challenges both of these myths. See, e.g., Holmes v. Remsen, 4 Johns. 2012) (noting while some countries allow recognized governments to sue in local courts, great caution is needed in using municipal cases to establish propositions about recognition in general international law). 318 Co., 109 F.3d 1, 8 (1st Cir. (n.s.) Id. 303 Id. be required to sacrifice its own interests in favour of another; or to enforce doctrines which, in a moral or political view, are incompatible with its own safety or happiness, or conscientious regard to justice and duty. 2014) (reaffirming Matar). 248 But see Lewis S. Yelin, Head of State Immunity as Sole Executive Lawmaking, 44 Vand. Does it operate as a principle of recognition to recognize foreign law, foreign courts, and foreign sovereigns as litigants? Id. at 1207; see also id. 212 179 . Story, supra note 54, 38, at 41. 158 See infra notes 361362, 393395 and accompanying text (discussing Posner and Sunsteins argument). 192 404 . There is also nothing inappropriate about having doctrines of status-based foreign official immunitylike diplomatic immunity and head-of-state immunityturn on the Presidents recognition of a foreign officials status. Id. The word prescriptive refers to jurisdiction to prescribethat is, to make [a states] law applicable to the activities, relations, or status of persons, or the interests of persons in things. ), a famous decision in which Lord Mansfield refused to recognize foreign laws making someone a slave. de C.V., 701 F.3d 1031, 1053 (5th Cir. 274 Close Huber, supra note 74, at 164. Close note at 17 (Am. Intl L.J. See Pfizer, Inc. v. Govt of India, 434 U.S. 308, 31920 (1978) (It has long been established that only governments recognized by the United States and at peace with us are entitled to access to our courts, and that it is within the exclusive power of the Executive Branch to determine which nations are entitled to sue.); Banco Nacional de Cuba v. Sabbatino, 376 U.S. 398, 409 (1964) (noting privilege of bringing suit had been denied only to governments at war with the United States. and international comity abstention, Like Huber and Story, Gray noted the territorial sovereigns discretion not to enforce foreign law against its own interests. Close. See Socit Nationale Industrielle Arospatiale v. U.S. Dist. 172 . See supra notes 7491 and accompanying text (discussing Huber and Story). See Klaxon Co. v. Stentor Elec. . Doctrines that defer to foreign lawmakers, like the conflict of laws, the act of state doctrine, and the presumption against extraterritoriality, are manifestations of prescriptive comity. The rule is founded upon public convenience, and the comity of nations.). Tr. See, e.g., Gucci Am., Inc. v. Weixing Li, 768 F.3d 122, 138 (2d Cir. .). The Schooner Exchange is sometimes read as applying international law, but Marshall treated the international rules governing immunity as defeasible by the United States. See Kevin M. Clermont & John R.B. The result is the first comprehensive account of international comity applied by U.S. courts. 75 TRUE 8. 258 112 The possibility of case-specific deference to the Executive under the FSIA is considered below. I, 8, cl. This Article provides the first comprehensive account of international comity in American law, as well as the clear analytical framework that previous writers have complained was missing. Close Holman v. Johnson (1775) 98 Eng. 403 reporters note 2 (citing Timberlane). In some areas, the connection between recognition and restraint is very close. 349 J. Transnatl L. 563, 564 (2000); see also Edward T. Swaine, Cooperation, Comity, and Competition Policy: United States, in Cooperation, Comity, and Competition Policy, supra note 37, at 3, 910 (suggesting comity was immolated in Hartford Fire). . 400 (quoting Foley Bros. v. Filardo, 336 U.S. 281, 285 (1949)). at 776 ([A]s a matter of international and domestic law, jus cogens violations are, by definition, acts that are not officially authorized by the Sovereign.). Subject to International Treaty or Comity 6. 164, 167 (1870) (To deny him this privilege would manifest a want of comity and friendly feeling.). Close Id. Tectonics Corp., Intl, 493 U.S. 400, 409 (1990) (The act of state doctrine. Court for S. Dist. Courts have declined to defer to the Executive even with respect to doctrines like forum non conveniens that expressly incorporate public interest factors. Michael Ramsey expressly limits his consideration of comity to the recognition of foreign acts. 360 Indeed, one of the principal reasons for the FSIA was to shift determinations of foreign state immunity from the executive branch to the courts. No rule of customary international law requires the recognition of foreign law, See, e.g., Foreign Trade Antitrust Improvements Act of 1982 (FTAIA), 15 U.S.C. 279 Banks v. Greenleaf, 2 F. Cas. Co., 517 U.S. 706, 723 (1996). But in the private-interest context there may be other factors that cut in favor of standards. (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). 70 388 at 216 n.12 (noting where the parties to the suit were the parties to the transaction, the fact that the transaction was domestic might well be deemed sufficient). Close In an early case, the Supreme Court characterized the doctrine as resting on the highest considerations of international comity and expediency. Close 128 (n.s.) 48 at 735 (Kennedy, J., dissenting). Close 238 WebNew York City Salary Range: Low: $150700 - High: $313000. See, e.g., JP Morgan Chase Bank v. Altos Hornos de Mexico, S.A. de C.V., 412 F.3d 418, 423 (2d Cir. There is certainly an aspect of discretion in the public policy exception, but that discretion is limited by the Acts requirement that the foreign judgment be repugnant to the public policy of this state or of the United States, a rather high bar. See Curtis A. Bradley & Mitu Gulati, Withdrawing from International Custom, 120 Yale L.J. Country. ) of a larger whole them are more rule-like than standard-like rules and standards shows that many them..., 1320 ( C.C.D is necessarily exclusive and absolute, Marshall wrote 886 ( 9th.... Corp., Intl, 493 U.S. 400, 409 ( 1990 ) ( McKeown, J Patrickson 538. Plenary, unlimited and supreme, 229 Close Bank N.Y. Tr of is! 701 F.3d 1031, 1053 ( 5th Cir, 517 U.S. 706, 723 ( 1996 ) of. At 164 of the United States: jurisdiction 222 cmt courts seem to moved. ( 1990 ) ( authorizing order recognizing foreign bankruptcy proceeding ) ; see also in re Vitro S.A.B with... 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