in-print-bilateral-benefits-0409-en

Debtsubstitute

Info iconThis preview shows page 1. Sign up to view the full content.

View Full Document Right Arrow Icon
This is the end of the preview. Sign up to access the rest of the document.

Unformatted text preview: e must be carefully evaluated before determining whether the requirements under this article have been met. QualIf yINg PersoN TesTs article xxix a(2) provides that a resident of Canada or the united states that is a qualifying person is entitled to all benefits accorded by the treaty. a qualifying person includes 1. a natural person; 2. the government of the united states or Canada, including a political subdivision, a local authority, or any agency or instrumentality of any such government, subdivision, or authority; 3. a company or trust whose principal class of shares or units (and any disproportionate class of shares or units) is primarily and regularly traded on one or more recognized stock exchanges; 4. a company, if five or fewer persons each of which is a company or trust referred to in (3) above own directly or indirectly more than 50 percent of the aggregate vote and the value of the shares and more than 50 percent of the vote and value of each disproportionate class of shares (in neither case including debt substitute shares),19 provided that each company or trust in the chain of ownership is a qualifying person; 5. either a. a company, 50 percent or more of the aggregate vote and value of whose shares and 50 percent o...
View Full Document

This note was uploaded on 11/03/2013 for the course ACCOUNTING 346 taught by Professor William during the Fall '12 term at DeVry Chicago.

Ask a homework question - tutors are online