The Resource LOB provisions in the 2015 draft U.S. Model tax treaty

LOB provisions in the 2015 draft U.S. Model tax treaty

Label
LOB provisions in the 2015 draft U.S. Model tax treaty
Title
LOB provisions in the 2015 draft U.S. Model tax treaty
Creator
Subject
Language
eng
Summary
This article examines proposals by the U.S. Treasury Department, which were released without a technical explanation, to modify the U.S. Model Treaty provisions that affect the limitation on benefits (LOB) article. The author believes that given the rules-based nature of the LOB article, new rules are needed as taxpayers find ways around the old ones and as the nature of what Treasury believes to be treaty abusive - such as low resident state tax treatment of income - evolves. The author discusses the provisions, with examples, and tries to make sense of them. In the end, he finds that the size and complexity of the LOB proposals suggest that a principal purpose test approach is worth considering
Citation source
In: Tax notes international. - Falls Church. - Vol. 80 (2015),
http://library.link/vocab/creatorName
Stone, M. (Mark)
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • LoB
  • US Model
  • treaty abuse
  • principal purpose test
Label
LOB provisions in the 2015 draft U.S. Model tax treaty
Instantiates
Publication
Label
LOB provisions in the 2015 draft U.S. Model tax treaty
Publication

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