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US and Mexico reach mutual agreement on eligibility of fiscally transparent entities to claim treaty benefits

16 October 2005

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Treaty Development

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United States-Mexico

The US Internal Revenue Service (IRS) has announced that the United States and Mexico have reached a mutual agreement regarding the eligibility of fiscally transparent entities to claim benefits under the Mexico-United States income tax treaty and amending protocols. The announcement was made in News Release IR-2005-107 dated 19 September 2005. The Agreement states that the Competent Authorities agree that in applying Para. 2(b) of the Protocol signed on 18 September 1992, dealing with the definition of residence in the case of partnerships, estates and trusts, it is understood that income from sources within one of the contracting states received...