Tuesday, November 26, 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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