Foreign partner receives business income from the interest o ...
The Supreme Tax Court has held that a foreign limited partner must accept attribution of the shares in a British distributor company held by the partners to the partnership. In consequence, the interest on a shareholder loan falls to the partnership, where it is requalified as trading income. The interest clause in the double tax treaty with the partner’s home country is inapplicable.
Kategorien: Supreme Tax Court cases
Schlagwörter: shareholder loan, partner, interest inco ...