International Tax

The accelerating growth in global trade has occasioned the creation of new types of cooperative enterprises. For example, companies routinely form joint ventures or other partnership arrangements to engage in isolated projects or systematically to conduct business. Various forms of limited liability companies are also business and investment vehicles in the global arena. The application of treaties to these companies and vehicles gives rise to problems because tax treaties do not deal with attribution of …

…if (i) the residence country of the company or individual deriving the income does not include the item in the income of a resident entity itself or of a resident participant of that entity; (ii) the treaty does not address the applicability of the treaty to income derived through a partnership; and (iii) the foreign country does not impose tax on a distribution of such item from the partnership to a partn! er. /3/ ------------------------------------------------------------------------ **Bibliography**