Published on 01 Oct 03
by "AUSTRALIAN TAX FORUM" JOURNAL ARTICLE
A key change to the Australia-United States income tax treaty effected by the recent Protocol was the replacement of the limitation on benefits (LOB) article with a new article consisting of revised LOB tests. This paper briefly considers certain historical and policy matters relating to LOB provisions and then compares the revised tests with the tests they replace and with corresponding provisions of certain model and other treaties.
John is a lawyer in the New York office of Shearman & Sterling LLP advising on United States federal income tax matters in the context of a broad range of commercial transactions. John is admitted in New York and New South Wales.
Current at 14 October 2003