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Tuesday, November 26, 2013

Clarifying the Meaning of 'Beneficial Owner' in Tax Treaties

Tax Analysys Logo (2013)Koichiro Yoshimura (LL.M. (Tax) 2014, NYU),  Clarifying the Meaning of 'Beneficial Owner' in Tax Treaties, 72 Tax Notes Int'l 761 (Nov. 25, 2013):

Koichiro Yoshimura looks at the meaning of the term "beneficial owner" in the OECD model income tax treaty, and through a functional analysis, attempts to set reasonable and more acceptable beneficial ownership criteria.

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http://taxprof.typepad.com/taxprof_blog/2013/11/clarifying.html

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