The Resource Impediments to financing foreign-owned U.S. business : recent developments in earnings stripping, anti-conduit, and treaty rules

Impediments to financing foreign-owned U.S. business : recent developments in earnings stripping, anti-conduit, and treaty rules

Label
Impediments to financing foreign-owned U.S. business : recent developments in earnings stripping, anti-conduit, and treaty rules
Title
Impediments to financing foreign-owned U.S. business : recent developments in earnings stripping, anti-conduit, and treaty rules
Creator
Subject
Summary
Describes the most significant of some developments in the U.S.A. and abroad influencing the traditional approaches to financing the operations of U.S. subsidiaries of foreign corporations. Among these developments are the radical expansion of the "earnings stripping" rules and the 1993 Act's grant of authority to the U.S. Treasury to write regulations recharacterizing multiple party "conduit" financing transactions as transactions between two parties. Other important developments relating to common uses of Netherlands companies in financing structures are the pending ratification of the new U.S.-Netherlands tax treaty, with its extensive anti-treaty shopping "limitation on benefits" provision and the negotiation of an "anti-triangular" protocol under art. 24(4) of the pending U.S.-Netherlands treaty, and the related publication of "anti-tax haven" legislative proposals by the Netherlands Ministry of Finance
Citation source
In: Tax Management International Journal. - Washington. - Vol. 22 (1993),
http://library.link/vocab/creatorName
  • Bennett, M.C
  • Morrison, P.D
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • conduit financing
  • earnings stripping
  • tax treaty
  • LoB
  • chain transaction
Label
Impediments to financing foreign-owned U.S. business : recent developments in earnings stripping, anti-conduit, and treaty rules
Instantiates
Publication
Label
Impediments to financing foreign-owned U.S. business : recent developments in earnings stripping, anti-conduit, and treaty rules
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...