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treaty benefits -- reverse hybrid Diggitydong August 21, 2011 04:50 pm
US public company parent has two US subsidiaries. The two US subsidiaries are partners in a UK partnership. The UK partnership makes a CTB election, so now it's a reverse hybrid: corp for US, partnership for foreign. If the US public company parent pays interest on a loan to the UK partnership, can the UK partnership or its two US partners assert treaty benefits to reduce the WHT from 30% to 0%?


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