The Resource Applying the New Zealand-U.S. income tax treaty to hybrid entities

Applying the New Zealand-U.S. income tax treaty to hybrid entities

Label
Applying the New Zealand-U.S. income tax treaty to hybrid entities
Title
Applying the New Zealand-U.S. income tax treaty to hybrid entities
Creator
Subject
Language
eng
Summary
Proper planning of New Zealand-U.S. transactions can assure benefits under the 2005 Competent Authority mutual agreement, but not all hybrids qualify. This article is organized as follows: (1) an overview of business entities permitted under U.S. law and the U.S. federal taxation of these business entities and their owners; (2) a description of the U.S. check-the-box Regulations that permit many, but not all, business organizations to elect their tax treatment for U.S. federal income tax purposes as either (a) a not fiscally transparent taxable corporation or (b) a fiscally transparent non-taxable pass-through (these Regulations spawned many of the U.S. hybrids that now exist); (3) background of the NZ-U.S. DTA; (4) an examination of what is a "hybrid entity"; (5) a review of the 2005 Agreement; and (6) concluding comments. The analysis includes discussion of (1) the 2005 Organization for Economic Cooperation and Development Model Tax Convention; (2) the 1996 and 2006 U.S. Model Tax Conventions; and (3) the 2005 Competent Authority mutual agreement
Citation source
In: Journal of international taxation. - New York. - Vol. 19 (2008),
http://library.link/vocab/creatorName
Lischer, H.J. (Jr.)
Language note
English
http://library.link/vocab/subjectName
  • tax treaty
  • MAP
  • hybrid entity
  • check-the-box regulations
Label
Applying the New Zealand-U.S. income tax treaty to hybrid entities
Instantiates
Publication
Label
Applying the New Zealand-U.S. income tax treaty to hybrid entities
Publication

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