International Tax Blog: 894 Limitation on Benefits

894 Limitation on Benefits

June 15, 2021

13 New Charts Published

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Posted on June 15, 2021 in 301 Distributions, 368 Corporate Reorgs, 701 Partnerships, 879 Community Property, 894 Limitation on Benefits, Authority - Revenue Rulings, Charts - Situational Charts | Permalink

April 09, 2021

US Treaty Limitation on Benefits Status Map

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Posted on April 09, 2021 in 894 Limitation on Benefits | Permalink

August 05, 2016

IRS International Practice Units By Category

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Posted on August 05, 2016 in 1441 U.S. Withholding Taxes, 163(j) Earnings Stripping, 367(b) Fgn to Fgn Corp, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 6048 Foreign Trusts, 7701(b) Individual Residency, 861 Source of Income, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 911 Housing Cost Amounts, 951 Subpart F Income, 956 Investments in U.S. Property, 988 Transactions, 989 Qualified Business Unit (QBU), Other - IRS Practice Units | Permalink

May 10, 2016

Tax Treaty Limitation on Benefits (“LOB”) & Form W8-BEN-E

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Posted on May 10, 2016 in 894 Limitation on Benefits, 894 Treaties, Form W-8 BEN / BEN-E | Permalink

December 23, 2014

I.R.S. International Practice Units

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Posted on December 23, 2014 in 163(j) Earnings Stripping, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 7701(b) Individual Residency, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 911 Foreign Earned Income Exclusion, 951 Subpart F Income, Form 2555, Other - IRS Practice Units | Permalink

November 02, 2013

International PLRs for the 43rd week of 2013

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Posted on November 02, 2013 in 1(h)(11) Qualified Dividend Income, 701 Partnerships, 861 Source of Income, 894 Limitation on Benefits, 894 Treaties, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891 | Permalink

July 07, 2011

Is the Limitation On Benefits Provision in the Proposed Hungary Treaty Too Complex?

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Posted on July 07, 2011 in 894 Limitation on Benefits | Permalink

June 27, 2011

Flowchart of LOB Article of Chile-U.S. Income Tax Treaty

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Posted on June 27, 2011 in 894 Limitation on Benefits, Charts - Flowcharts | Permalink