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Article: Anti-treaty shopping restrictions in the new U.S.-Netherlands tax treaty.
- Article from:
- Tax Executive
- Article date:
- September 1, 1993
- Author:
CopyrightCOPYRIGHT 1993 Tax Executives Institute, Inc. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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Introduction
The recently negotiated income tax treaty between the United States and the Netherlands [hereinafter Netherlands-2 Treaty] (1*) and accompanying protocol [hereinafter Netherlands-2 Protocol](2) contain a series of detailed anti-treaty shopping rules that have hitherto been absent in U.S. bilateral tax treaties. Intended primarily to update the antiquated U.S.Netherlands Treaty of 1948 [hereinafter Netherlands-l Treaty],(3) the new treaty represents the U.S. Treasury Department's most successful effort at extending into actual treaty formation extant U.S. statutory and regulatory restrictions on the use of a treaty by residents of a third nation.
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