U.S. IRS Memorandum on Application of Treaties to Branch Profits Tax of Certain Hybrid Entities

The U.S. IRS has published a memorandum from the Office of Chief Counsel on the Application of Treaties to Branch Profits Tax of Certain Hybrid Entities. The key point of the memorandum is that treaty relief from the U.S. branch profits tax for hybrid entities must be determined at the owner level, not the entity level, based on each owner's residency, tax status, and qualification under the a…
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