Application of U.S. treaties to hybrid entities

Resource Information

The work Application of U.S. treaties to hybrid entities represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Application of U.S. treaties to hybrid entities

Creator

• Connors, P.J
• Femia, R.V

Subject

• domestic reverse hybrid entity
• hybrid entity
• OECD Model
• transparency
• tax treaty
• US Model

Language

eng

Summary

This article reviews recent guidance relating to the application of tax treaties to hybrid entities. It begins with a look back at significant developments of the 1990's, including the relevant provisions of the 1996 U.S. Model Income Tax Treaty, the commentaries to the OECD Model Income Tax Treaty, and U.S. Treasury regulations. Next, it reviews the recent relevant guidance relating to the U.S. income tax treaties with the United Kingdom, the Netherlands, Japan and Mexico. Finally, it introduces tax treaty issues raised by hybrid entities beyond the basic issue of entitlement to treaty rates of withholding tax

Citation source

In: Tax management international journal. - Washington. - Vol. 35 (2006),

Language note

English