The US Internal Revenue Service (IRS) is increasing its efforts to ensure that non-US entities, including Luxembourg investment funds, comply with US tax rules.
Tax authorities seem particularly focused on the following implications:
Making US investments may lead to US tax compliance obligations:
A company claiming treaty benefits should not only be a resident of the tax treaty partner, but must also satisfy the limitation on benefits (LOB) provision included in most US income tax treaties. Appropriate LOB analysis should, therefore, be made prior to claiming treaty benefits... click here to read more
