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

19 February 2006

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Treaty Development

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United States-Mexico

The United States and Mexico signed a revised mutual agreement on 22 December 2005 regarding the eligibility of fiscally transparent entities to claim benefits under the 1992 Mexico-United States income tax treaty and amending protocols. The new agreement supersedes and clarifies the mutual agreement signed by the Competent Authorities of the two countries on 26 August 2005. The new 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 resident in the case of partnerships, estates, and trusts, it is understood that income from sources...