Explanation of Proposed Protocol to the Income Tax Treaty Between the United States And Belgium : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On August 9, 1988 Jcs-13-88

Cover Explanation of Proposed Protocol to the Income Tax Treaty Between the United States And Belgium : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On August 9, 1988 Jcs-13-88
Explanation of Proposed Protocol to the Income Tax Treaty Between the United States And Belgium : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On August 9, 1988 Jcs-13-88
United States. Congress. Joint Committee On Taxation
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The U.S. model allows benefits to I ?enied if 75 percent or less of a resident company's stock is held fc individual residents of the country of residence, while the propose protocol (like several newer treaties and an anti-treaty shoppin provision in the Internal Revenue Code) lowers the qualifying pe' centage to 50, and broadens the class of qualifying shareholders t include residents of either treaty country (and citizens of th United States). Thus, this safe harbor is considerably easier t ...enter under the proposed protocol. On the other hand, counting fc this purpose shareholders who are residents of either treaty cour try would not appear to invite the type of abuse at which the prov son IS aimed, since the targeted abuse is ownership by third-cour try residents attempting to obtain treaty benefits.
Another provision of the anti-treaty shopping article of the pre posed protocol, which is coupled with the ownership requirement t achieve rate reduction benefits, is the "base erosion" rule.


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