Document Type
Article
Publication Date
8-2024
Abstract
Part 1 of this column discussed the choice between the limitation on benefits and principal purpose test (PPT) and the history of the LOB in U.S. tax treaty policy.
How effective is the LOB article in U.S. tax treaties, now that it no longer includes the PPT from the original U.S. LOB?
Recommended Citation
Avi-Yonah, Reuven S. "Limitation on Benefits or Principal Purpose Test? Part 2." Tax Notes International 115 (2024): 1033.
Comments
Reprinted with the permission of Tax Analysts.