The Resource Continued problems for U.S. resident members of LLCs seeking treaty benefits on Canadian source income - Canadian branch tax

Continued problems for U.S. resident members of LLCs seeking treaty benefits on Canadian source income - Canadian branch tax

Label
Continued problems for U.S. resident members of LLCs seeking treaty benefits on Canadian source income - Canadian branch tax
Title
Continued problems for U.S. resident members of LLCs seeking treaty benefits on Canadian source income - Canadian branch tax
Creator
Subject
Language
eng
Summary
The Fifth Protocol was touted by the governments of Canada and the United States as solving the thorny issues surrounding the status of U.S. LLCs under the Treaty.This article discusses Canadian branch tax, treaty benefits for fiscally transparent entities, and application of the Protocol to LLC and branch profits tax
Citation source
In: International tax journal. - Chicago. - Vol. 39 (2013), no. 6 (November-December) ; p. 17-20, 69-70
http://library.link/vocab/creatorName
  • Turner, C.M
  • Leitner, A
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • limited liability company
  • branch tax
  • treaty benefits
  • treaty interpretation
Label
Continued problems for U.S. resident members of LLCs seeking treaty benefits on Canadian source income - Canadian branch tax
Instantiates
Publication
Label
Continued problems for U.S. resident members of LLCs seeking treaty benefits on Canadian source income - Canadian branch tax
Publication

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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