Norway-U.S. Agreement Clarifies Treaty Eligibility for Disregarded Entities

Norway-U.S. Agreement Clarifies Treaty Eligibility for Disregarded Entities

The January 31 competent authority agreement between Norway and the United States expands on the fiscal residence provisions of the existing treaty to bring the language in line with recent treaties.
 
The 1971 Norway-U.S. tax treaty (amended by a 1980 protocol and clarified by a 2012 competent authority agreement) establishes that treaty benefits are available to a "partnership, estate, or trust" to the extent that the income is taxable in the contracting state. The new agreement establishes that both the United States and Norway will interpret this provision to include all entities considered "fiscally transparent" in either country.

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