Russia's Ministry of Finance recently published Guidance Letter No. 03-08-05/80345 on the taxation of income of a resident company of the Cayman and British Virgin Islands, the Isle of Man, the Channel Islands (including Jersey and Guernsey), and Gibraltar from sources in Russia. In particular, the letter addresses whether the provisions of the 1994 Russia-UK income and capital tax treaty may be applied in respect of these UK Crown Dependencies and Overseas Territories. The letter notes that these territories are not included within the definition of the "United Kingdom" as provided in paragraph (1)(a) of Article 3 (General Definitions) of...