Greedy Associates Boards   |  Threaded Discussion Forums   |  Newsletter
Greedy Tax Board
Where Tax Attorneys are in rare form
 

Home | Messages | Photos | Links | Contacts | Contact Administrators | FAQ | Newsletter |

Message 15599 of 15599 <- Previous | View All | Reply | Post

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%?

   

Message 15599 of 15599 <- Previous | View All | Reply | Post

Search:
   Go to: Oldest | Most Recent or msg #



Find Legal Jobs:

Message Board Terms of Use and Disclaimer
FindLaw
800 West California Avenue, 2nd Floor, Sunnyvale, CA 94086
Tel: (888) 257-9500;    Fax: (408) 524-4798;    Contact Us
Privacy policy  Site Contents © 1999-2006  Terms of service