Tuesday, March 08, 2005

A Loss to U.S. International Tax

According to the NY Times, Sidney I. Roberts, died last Saturday. Although I am not from his generation, I had the pleasure to read one of his reference articles "The Agency Element of Permanent Establishment: The OECD Commentaries from the Civil Law View," published in Intertax (1993). This article was for me very important to understand the background and interaction between Article 5(5) and (6) of the OECD Model.

See Below the news reported by NYT:

Sidney I. Roberts, a lawyer whose voluminous work in tax law is considered an authoritative source on how United States taxes apply to people and businesses from other countries, died on Saturday at home in Manhattan. He was 91.
As early as the 1940's, Mr. Roberts recognized the growing importance of tax law and worked to clarify and classify its growing provisions, especially those that affected foreign corporations.
He edited or helped write at least 10 books on taxation and produced dozens of scholarly articles on the tax implications of dual residences, international stock holdings and other offshoots of a global economy. Roberts & Holland, which he helped start in 1957, became the country's largest law firm devoted to taxation.
In 1967, he and William C. Warren wrote their influential work, "U.S. Income Taxation of Foreign Corporations and Nonresident Aliens."
As a testament to his influence on the practice of international tax law, more than 30 tax specialists worldwide collaborated to produce "Essays on International Taxation: In Honor of Sidney I. Roberts" (Kluwer, 1993), a book published on the occasion of his 80th birthday.
Mr. Roberts was born in Brooklyn on Nov. 29, 1913. He received his bachelor's degree from City College and law degree from Harvard, where he was editor of the Harvard Law Review.
From 1938 to 1949, he practiced tax law at accounting firms. He then helped develop the tax practice at Roosevelt, Freidin & Littauer, a law firm. He retired from Roberts & Holland as a partner in 1986 and remained involved with the firm until 1994.


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