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What happens when business entity classifications conflict? JOHN MCLEAN discusses the double taxation implications
KEY POINTS
- The basic principles of double tax relief.
- What are the US and UK basic taxing rights?
- The problem with a US limited liability company.
- Determining whether an entity is transparent or opaque.
- Is there a way to avoid the double tax problem?
To achieve their principal aim of protecting taxpayers against being taxed twice on the same income tax treaties based on the OECD model rely on the matching of income and capital gains that are taxable in one contracting state with items which are taxable in the other.
In the general case this is not problematic – income derived by a resident R of jurisdiction X from a source in jurisdiction Y may be taxed in both X and Y
but the treaty between X...
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