U.S. Income Tax Treaties -- the Limitation on Benefits Article PDF Download
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Author: Michael J. Miller
Publisher:
ISBN: 9781633593565
Category : Double taxation
Languages : en
Pages :
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Book Description
" ... discusses in detail the limitation on benefits (LOB) article of U.S. income tax treaties."--Portfolio description (page (iii)).
Author: Michael J. Miller
Publisher:
ISBN: 9781633593565
Category : Double taxation
Languages : en
Pages :
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Book Description
" ... discusses in detail the limitation on benefits (LOB) article of U.S. income tax treaties."--Portfolio description (page (iii)).
Author: Netherlands
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 24
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Book Description
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 28
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Book Description
Author:
Publisher: DIANE Publishing
ISBN: 9781422321157
Category :
Languages : en
Pages : 94
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Book Description
Author: Karl P Sauvant
Publisher: Oxford University Press
ISBN: 0199745188
Category : Law
Languages : en
Pages : 795
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Book Description
Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.
Author: Félix Alberto Vega Borrego
Publisher: Kluwer Law International B.V.
ISBN: 9041161430
Category : Law
Languages : en
Pages : 338
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Book Description
Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Author: United States. Congress. Joint Committee on Internal Revenue Taxation
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 1510
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Book Description
Author:
Publisher: DIANE Publishing
ISBN: 9781422321140
Category : Double taxation
Languages : en
Pages : 106
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Book Description
Author:
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 52
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Book Description
Author: M.J. Miller
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
Nearly all U.S. income tax treaties include a "Limitation on Benefits" (LOB) Article that generally requires a resident of a foreign country that is party to a U.S. income tax treaty (a "treaty country") to have one of certain specified connections to such country (or possibly the United States or certain other treaty countries) in order to access such treaty. The LOB Article is intended to limit the ability of third-country residents to engage in "treaty shopping" by establishing legal entities in treaty countries with which they otherwise have no meaningful connection.The LOB Article includes a number of objective tests. The common objective tests include (1) a public company test, (2) an ownership and base erosion test, (3) an active trade or business test, and (4) in some cases, a derivative benefits test.
