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U.S. IRS Publishes Competent Authority Arrangement with South Korea Clarifying Fiscal Domicile

11 December 2017

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Treaty Development

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United States-Korea, Rep of

The U.S. IRS has published the competent authority arrangement with South Korea regarding the application of certain provisions of Article 3 (Fiscal Domicile) of the 1976 U.S.-South Korea tax treaty, including the treatment of corporations and individuals as resident of a Contracting State. The arrangement was signed 7 March and 10 April by the U.S. and South Korea, respectively, and applies from the latter date of signature.