Limitation of benefits restricts treaty privileges unless an entity qualifies under residency, ownership, active business, and bona fide purposes. Limitation of Benefits confines treaty benefits to non individual residents who qualify as government entities, listed or predominantly resident owned companies, resident owned partnerships, or resident charitable/tax exempt entities, provided that not more than half their gross income is paid to non residents as deductible payments, subject to exceptions for arm's length business payments and certain banking obligations.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Limitation of benefits restricts treaty privileges unless an entity qualifies under residency, ownership, active business, and bona fide purposes.
Limitation of Benefits confines treaty benefits to non individual residents who qualify as government entities, listed or predominantly resident owned companies, resident owned partnerships, or resident charitable/tax exempt entities, provided that not more than half their gross income is paid to non residents as deductible payments, subject to exceptions for arm's length business payments and certain banking obligations.
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