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Treaty between US and Norway – IRS releases competent authority agreement regarding fiscally transparent entities

04 May 2013

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Treaty Development

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Norway; United States

13 February 2013 Report from Wooje Choi, IBFD North America The US Internal Revenue Service (IRS) has released the official text of the recent competent authority agreement between the United States and Norway regarding the eligibility of fiscally transparent entities to benefit under the 1971 US-Norway Income Tax Treaty (the Treaty), as amended by the protocol of 19 September 1980. The agreement clarifies: -   the cases in which entities that are treated as fiscally transparent under the laws of either the United States or Norway are eligible to claim benefits under the Treaty; and -   the procedure for claiming treaty benefits from...