Law Office of Charles W. Cope, PLLC | U.S. Income Tax Treaties - Qualification for Benefits
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U.S. Income Tax Treaties - Qualification for Benefits

Mr. Cope issued an opinion to a foreign mulitnational that one of its subsidiaries qualified for the benefits of the relevant U.S. income tax treaty under the active trade or business provision of the article on limitation on benefits.  This resulted in a substantial saving of U.S. income tax to the subsidiary.