TaxTMI 
TaxTMI 
Other Income
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.... fee arising in a Contracting State and characterized as other income by that Contracting State and beneficially owned by a resident of the other Contracting State that is a connected person with respect to the payor of the guarantee fee may be taxed in the first-mentioned Contracting State in accordance with domestic law if such resident benefits from a special tax regime with respect to the guar....
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....c entity immediately after the date on which the acquisition of the domestic entity is completed; and (B) prior to that date, was never a connected person with respect to the domestic entity. However, an entity described in the preceding sentence shall become an expatriated entity if, subsequent to the date on which the acquisition of the domestic entity is completed, the entity joins ....