The Resource Anti-deferral and anti-tax avoidance : when derivative benefits and zero withholding on dividends collide : are any treaty benefits available?

Anti-deferral and anti-tax avoidance : when derivative benefits and zero withholding on dividends collide : are any treaty benefits available?

Label
Anti-deferral and anti-tax avoidance : when derivative benefits and zero withholding on dividends collide : are any treaty benefits available?
Title
Anti-deferral and anti-tax avoidance : when derivative benefits and zero withholding on dividends collide : are any treaty benefits available?
Creator
Subject
Language
eng
Summary
A number of US income tax treaties include a "derivative benefits" provision that allows a corporation that does not otherwise satisfy the requirements of the treaty's limitation on benefits (LOB) article to qualify for the treaty benefits if, among other requirements, substantially all of the corporation's shares are owned by seven or fewer "equivalent beneficiaries". This article discusses the limitation of benefits article, derivative benefits test, interaction of derivative benefits with zero withholding on dividends (examples from the UK and Dutch treaty), reconciling the examples with the treaty language, and ability of taxpayers to rely on the examples
Citation source
In: International tax journal. - Chicago. - Vol. 33 (2007),
http://library.link/vocab/creatorName
Miller, M.J
Language note
English
http://library.link/vocab/subjectName
  • tax treaty
  • treaty benefits
  • derivative benefits
  • LoB
  • withholding tax
Label
Anti-deferral and anti-tax avoidance : when derivative benefits and zero withholding on dividends collide : are any treaty benefits available?
Instantiates
Publication
Label
Anti-deferral and anti-tax avoidance : when derivative benefits and zero withholding on dividends collide : are any treaty benefits available?
Publication

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