The Ukraine State Tax Service recently issued a guidance letter concerning the tax treatment of royalty payments where the recipient is not the actual beneficial owner. The letter addresses questions from a Ukraine entity that entered into an agreement with Stanford University, a U.S. resident, that involved the payment of royalties to a stand-alone division of Stanford. The letter clarifies that if the recipient of the Ukraine-source income is a non-resident that is not the beneficial owner, the income may be taxed in accordance with an applicable tax treaty between Ukraine and the state of residence of the actual beneficial...