in-print-bilateral-benefits-0409-en

Thisinterpretationisconsistentwiththeprincipleexpresse

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Unformatted text preview: us-Netherlands treaty, supra note 25; the united states, Department of the Treasury, Technical Explanation to the us-germany treaty signed on July 17, 2007; the united states, Department of the Treasury, Technical Explanation to the us-belgium treaty signed on July 17, 2007; the united states, Department of the Treasury, Technical Explanation to the us-Denmark treaty signed on July 17, 2007; and the united states, Department of the Treasury, Technical Explanation to the us-Finland treaty signed on July 17, 2007. 36 Technical interpretation no. 2007-0257021E5, July 16, 2008. i nternational tax planning n 101 n usco owns all of the shares of various us-resident operating corporations (us n usco receives dividend income from us Opcos and pays dividends to CanuLC, Opcos), which carried on active businesses in the united states. which in turn pays dividends to us Holdco. The structure is depicted in figure 2. The issue in question was the applicable rate of Canadian withholding tax for dividends paid by CanuLC to us Holdco under the protocol. in determining wheth...
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