Application of U.S. Treaties to Hybrid Entities

Tax Management International Journal
03.10.06
Rocco Femia's article states that hybrid entities play a significant role in international tax planning. The application of income tax treaties to hybrid entities raises substantial technical and policy issues. These issues drew considerable attention from practitioners and policymakers in the 1990s, leading to significant developments in the United States and internationally.
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BNA.TaxManagementInternationalJournal.0310.06
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