IRS Memorandum Clarifies Non-Residents May Not Claim Treaty Benefits with Respect to DISC Distributions
The U.S. IRS has published a memorandum dated 4 November 2022 from the Office of Chief Counsel concerning treaty benefits for distributions and gains with respect to the stock of a Domestic International Sales Corporation (DISC). The main issue and conclusion are as follows:
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ISSUE
Are foreign taxpayers permitted to claim a reduced rate of U.S. tax on their DISC distributions under Arti…
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