The Revenue Rule and International Tax Collection

November 17, 2021

Governments seeking to recoup tax liabilities outside their borders often face a substantial hurdle in the form of the “Revenue Rule,” the long-standing common law doctrine that precludes countries from enforcing one another’s revenue laws. In his latest column for the New York Law Journal, “The Revenue Rule and International Tax Collection,” Jeremy Temkin discusses the Revenue Rule and the apparent lack of enthusiasm for non-judicial Mutual Collection Assistance Requests designed to bypass its limitations. Although the case law and international agreements will continue to shape international tax collection in the years to come, the Revenue Rule’s prohibition has remained constant for over two centuries and shows no meaningful sign of waning.