The Resource New US model treaty broadens scope of residence and increases availability of benefits to "fiscally transparent entities" and their members

New US model treaty broadens scope of residence and increases availability of benefits to "fiscally transparent entities" and their members

Label
New US model treaty broadens scope of residence and increases availability of benefits to "fiscally transparent entities" and their members
Title
New US model treaty broadens scope of residence and increases availability of benefits to "fiscally transparent entities" and their members
Creator
Subject
Language
eng
Summary
This article is an analysis of the residence definition in article 4 of the 1996 US model treaty. The article describes the issues of treaty interpretation that arise when using fiscally transparent entities to effect cross-border transactions, especially as regards the residence principle. The authors give possible solutions and review the policy choices of the U.S. with respect to fiscally transparent entities
Citation source
In: Journal of international taxation. - New York. - Vol. 8 (1997),
http://library.link/vocab/creatorName
  • Tan Majure, K.J
  • Lindholm, N.S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • tax transparency
  • residence
  • treaty interpretation
  • hybrid entity
Label
New US model treaty broadens scope of residence and increases availability of benefits to "fiscally transparent entities" and their members
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/1997/J/JOUROFINT/4_164-171.zip
Publication

Library Locations

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