Willens, Robert
U.K.-U.S. treaty residency requires more than full taxation / by Robert Willens .-- , 2024
Robert Willens is president of Robert Willens LLC and an adjunct professor at Columbia Business School. In this article, Willens examines a case recently decided in the U.K. Court of Appeal that held that a U.K.-based General Electric Co. subsidiary was liable for U.K. tax on its interest income and was not entitled to relief under the U.K.-U.S. income tax treaty despite being a stapled entity with a local company.
RESIDENCIA FISCAL
IMPUESTO SOBRE LAS RENTAS DEL CAPITAL
FISCALIDAD INTERNACIONAL
CONVENIOS
ESTADOS UNIDOS
REINO UNIDO
Tax Notes International 1048-3306 v. 116, n. 3, October 21 2024; p. 469-472
U.K.-U.S. treaty residency requires more than full taxation / by Robert Willens .-- , 2024
Robert Willens is president of Robert Willens LLC and an adjunct professor at Columbia Business School. In this article, Willens examines a case recently decided in the U.K. Court of Appeal that held that a U.K.-based General Electric Co. subsidiary was liable for U.K. tax on its interest income and was not entitled to relief under the U.K.-U.S. income tax treaty despite being a stapled entity with a local company.
RESIDENCIA FISCAL
IMPUESTO SOBRE LAS RENTAS DEL CAPITAL
FISCALIDAD INTERNACIONAL
CONVENIOS
ESTADOS UNIDOS
REINO UNIDO
Tax Notes International 1048-3306 v. 116, n. 3, October 21 2024; p. 469-472