TITLE

Anti-Deferral and Anti-Tax Avoidance

AUTHOR(S)
Glicklich, Peter; Leitner, Abraham; MacDonald, Jennifer
PUB. DATE
January 2008
SOURCE
International Tax Journal;Jan2008, Vol. 34 Issue 1, p5
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
The article focuses on the U.S.-Canada Protocol that contains Novel hybrid entity provision as part of their anti-deferral and anti-tax avoidance. According to the author, U.S. hybrid entities are typically limited liability companies (LLCs), under the 1997 default classified regulations as partnerships if they have more than one member or as entities disregarded as separate from their owner if they have a single member. However, the provisions contained in the Protocol have provoked controversy among U.S. and Canadian tax professionals who had been looking forward to some relief from the unfavorable treatment of hybrids in the existing treaty.
ACCESSION #
28543237

 

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