U.S. IRS Publishes Competent Authority Arrangement with South Korea Clarifying Fiscal Domicile
The U.S. IRS has published the competent authority arrangement with South Korea regarding the application of certain provisions of Article 3 (Fiscal Domicile) of the 1976 U.S.-South Korea tax treaty, including the treatment of corporations and individuals as resident of a Contracting State. The arrangement was signed 7 March and 10 April by the U.S. and South Korea, respectively, and applies f…
Continue Reading