US and Norwegian tax authorities address treaty eligibility for fiscally transparent entities

February 2013


On January 31, 2013, the IRS announced the signing of a competent authority agreement between Norway and the United States addressing the circumstances in which an item of income paid to an entity that is fiscally transparent under the tax laws of either jurisdiction will be seen as received by a resident of one of the two countries. The agreement specifically identifies disregarded LLCs, subchapter S corporations, grantor trusts, and common trust funds as entities that are fiscally transparent for US tax purposes and details the procedures that each entity must follow in order to claim treaty benefits from Norway.

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