8854414
9781845925505
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This detailed commentary on the UK/US Double Tax Treaty covers the purpose of treaties, background to the convention, a general discussion on treaty trends and the OECD. The publication consists of a detailed analysis of each article, including: the text of the relevant article in full; an overview outlining the need for the article and its broad effect indicating any significant differences from the OECD or US model treaties; a discussion of the key terms highlighting any developments and differences since the old treaty and commenting on the interaction with other treaty articles; envisaged difficulties in application or contentious issues including areas that the treaty does not address or adequately provide for; reference to relevant commentaries from US or UK authorities and a general explanation of any available planning opportunities using the article e.g. standard structures or treaty uses.Ernst Young Staff is the author of 'Guide to the Uk/Us Tax Treaty' with ISBN 9781845925505 and ISBN 1845925505.
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