The Convention between the Government of the United States of America and the Government of the State of Israel with Respect to Taxes on Income has reached its final stages of ratification. This is the third attempt of the two governments to reach agreement on tax questions of mutual interest. The United States Senate failed to ratify the first proposed convention because of the inclusion of a “tax sparing” clause. Although the second attempt would have granted U.S. taxpayers an investment credit for investments in Israel, in lieu of the tax sparing, this substitute was still not considered sufficiently neutral to accord it ratification.

The present attempt makes use of the foreign tax credit as its primary means of alleviating double taxation.

In Israeli law eighteen statutes now regulate the legal status of various kinds of disabled persons. These statutes apply to about twice the number of different categories of disabled persons, classified in groups or classes, according to the cause and circumstances of disablement. Ignoring voluntary arrangements, the number of legal statuses or classifications (i.e. the complex of legal rights, pecuniary and in specie, together with the conditions of entitlement) may be put at eleven, which includes groups of people disabled de facto who are not recognised as disabled under law since they do not come within the statutory definition of disablement or otherwise meet the conditions of entitlement. The number of statuses is smaller than the number of statutes because some of the latter merely extend the application of other statutes in pari materia.

If we address ourselves to the substance of the legal status of these disabled persons, the general impression obtained reflects a kind of order of preference among the different groups, sometimes with considerable gaps. At the lowest level are the most deprived, the de facto disabled, who lack all rights as such, and the ordinary disabled (those who do not fall into any specific category but are recognised as disabled—the “new” and “long-standing” invalids of Chapter 6B of the National Insurance Law (Consolidated Version), 1968, in respect of whom a paucity of rights exists, in the nature only of ultimum subsidium. At the upper level stand the most preferred groups under existing law, traffic-accident victims and disabled soldiers.

The “speciality principle” or “speciality rule”, governing extradition relations between States, finds its expression in the fact that the institution of extradition is intended, as far as its material grounds are concerned, to cover only a part of all criminal offences, that each case of the extradition of a particular person is closely connected with a specific offence and as a result of this, that the competence of the requesting State to try and punish him is limited by those restrictions imposed upon it, again from the material point of view, by the requested State.

The rule therefore, has two aspects, the “specificness of extradition” and the “limitation of competence”, which, although they are intertwined and interdependent, each has its own characteristics. They are to be viewed from the standpoint of the position of the State—whether as requested to extradite or requesting extradition—and the part the State plays in applying the principle.