U.K.-U.S. treaty residency requires more than full taxation by Robert Willens
By: Willens, Robert
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Material type: 
ArticlePublisher: 2024Subject(s): RESIDENCIA FISCAL | IMPUESTO SOBRE LAS RENTAS DEL CAPITAL | FISCALIDAD INTERNACIONAL | CONVENIOS | ESTADOS UNIDOS | REINO UNIDO
In:
Tax Notes International v. 116, n. 3, October 21 2024; p. 469-472Summary: 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.
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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.
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