Since the enactment of the Panama Canal Treaty (the Treaty) on October 1, 1979, United States citizens employed by the Panama Canal Commission have come to the United States federal courts seeking exemption from income taxation. The Commission employees have based their claims on an executive agreement which accompanied the Treaty. Specifically, they have relied on the language found in article XV of the Agreement in Implementation of Article III of the Panama Canal Treaty (the Implementation Agreement).
Pamela P. Bond,
The Perils of Panama--Are United States Employees of the Panama Canal Commission Exempt from United States Income Taxation?,
19 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vjtl/vol19/iss1/5