IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions
The book then turns to the question of whether provisions included in the tax code that are expressly designed to re-characterize or deal with transactions that are considered to result in unacceptable avoidance of tax under the code can be extended and applied where there is an unacceptable avoidance of tax by virtue of the application of a tax treaty provision.
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- Proceedings of the Seminar
- Addendum: Proposed Section 7701 (1) Regulations