Beneficial Ownership in case of conduit and back-to-back arrangements
March 17 2023
Open Access Video
This video discusses the beneficial ownership issues in case of conduit or back-to-back situations.
More videos in the Beneficial Ownership Series
Beneficial Ownership: How should that tax treaty term be interpreted?
Beneficial Ownership: Two Very important decisions
Beneficial Ownership: Is 'risk' a relevant factor for determination of beneficial ownership?
Beneficial Ownership: Absence of beneficial ownership clause in a tax treaty - implied inference and burden of proof (1)
Beneficial Ownership: Absence of beneficial ownership clause in a tax treaty - implied inference and burden of proof (2)
Variable interest on loans: Tax treaty characterization as dividends (Art. 10) or interest (Art. 11)?
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