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UK/US Tax Treaty

Mark Penney Tax Partner and Thomas Dick US Tax Director KPMG in the UK discuss the application of the UK/US treaty to hybrid entities
Mark Schofield and Eric Peden's UK/US tax treaty article on page 9 of this issue looks at a common issue in the UK/US treaty which is the complexity of the Limitation on Benefits article. Here we consider another common issue: the treatment of hybrids such as US 'check the box' entities.
The tax treatment of hybrid entities has been the subject of considerable focus by HMRC over the past couple of years highlighted by the enactment of the arbitrage legislation in Finance (No 2) Act 2005. It will not come as much surprise to readers to learn that the underlying...

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