This content is from: United States

US inbound update: Ruling restricts ability of foreign corporations to use US treaty benefits

Revenue Ruling 2004-76 held that a foreign corporation (A), formed under the laws of country X, could not claim the benefits of the income tax treaty between the US and country X if under the income tax treaty between country X and country Y, it is treated as a resident of country Y

To access our market-driven intelligence please request a trial here.

Read this article – and more – for a 30 day period.


Are you already an ITR subscriber? Log in here

Instant access to all of our content. Membership Options | 30 Day Trial