International Tax Report
Derivative benefits and equivalent beneficiaries: Reflecting on the 2016 US Model Income Tax Convention
In this article Flavia Cavalcanti Pepe and H. David Rosenbloom update their prior analysis of Derivative Benefits provisions under Limitation on Benefits (published in the October 2015 and November 2015 editions of International Tax Report) to reflect the recently issued 2016 US Model Income Tax Convention.