The Resource Application of U.S. treaties to hybrid entities

Application of U.S. treaties to hybrid entities

Label
Application of U.S. treaties to hybrid entities
Title
Application of U.S. treaties to hybrid entities
Creator
Subject
Language
eng
Summary
This article reviews recent guidance relating to the application of tax treaties to hybrid entities. It begins with a look back at significant developments of the 1990's, including the relevant provisions of the 1996 U.S. Model Income Tax Treaty, the commentaries to the OECD Model Income Tax Treaty, and U.S. Treasury regulations. Next, it reviews the recent relevant guidance relating to the U.S. income tax treaties with the United Kingdom, the Netherlands, Japan and Mexico. Finally, it introduces tax treaty issues raised by hybrid entities beyond the basic issue of entitlement to treaty rates of withholding tax
Citation source
In: Tax management international journal. - Washington. - Vol. 35 (2006),
http://library.link/vocab/creatorName
  • Connors, P.J
  • Femia, R.V
Language note
English
http://library.link/vocab/subjectName
  • hybrid entity
  • tax treaty
  • US Model
  • OECD Model
  • domestic reverse hybrid entity
  • transparency
Label
Application of U.S. treaties to hybrid entities
Instantiates
Publication
Label
Application of U.S. treaties to hybrid entities
Publication

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