This week, the United Kingdom Supreme Court, in a landmark decision, has ruled that a UK resident individual member of a Delaware limited liability company is entitled to credit in the UK for US tax…
Tax treaty rules to resolve the dual residence of persons other than individuals have been consistent since the 1963 OECD draft convention. Such dual residence in resolved by Article 4(3) of the OECD…
The claim for the so-called “single taxation principle”, in spite of its doubtful general acceptance, seems to have been acknowledged by the OECD, which has moved from a position whereby countries…
