Limitation of Benefit: treaty benefits denied where main purpose was to secure treaty advantages or taxpayer is not beneficial owner. Limitation of Benefit permits domestic anti abuse rules to determine treaty entitlement, denies benefits where a person is not the beneficial owner of income, preserves domestic Controlled Foreign Corporation rules, and bars benefits when the creation, presence, or transactions of a resident have as their main purpose or one main purpose the obtaining of treaty benefits that would not otherwise be available.
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 Benefit: treaty benefits denied where main purpose was to secure treaty advantages or taxpayer is not beneficial owner.
Limitation of Benefit permits domestic anti abuse rules to determine treaty entitlement, denies benefits where a person is not the beneficial owner of income, preserves domestic Controlled Foreign Corporation rules, and bars benefits when the creation, presence, or transactions of a resident have as their main purpose or one main purpose the obtaining of treaty benefits that would not otherwise be available.
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