Bucky Dent
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A blue star. And how it works is you stare at the blue star for thirty seconds and then you look at a blank sheet of paper and what you see is that you just wasted another goddam minute of your stupid life.

One of those hypnosis spinning-wheel things. Doesn’t seem like that big a deal, does it? Then how come you’re suddenly clucking like a chicken?

Eem wrote:By the way I tried to say GO FUCK YOURSELF Anthony Kiedis

swishnicholson wrote:Shouts and Murmurs in the New Yorker has been iffy lately, but New Optical Illusions by Dan Guterman made me LOL numerous times.

A blue star. And how it works is you stare at the blue star for thirty seconds and then you look at a blank sheet of paper and what you see is that you just wasted another goddam minute of your stupid life.

One of those hypnosis spinning-wheel things. Doesn’t seem like that big a deal, does it? Then how come you’re suddenly clucking like a chicken?

jeff2sf wrote:jeez-us andy, i'm fighting with like 97 people on this board, we can't be fighting too. I just saw a lot of negatives in your posts and busted your balls about it. I've never run into a triple negative by an intelligent person before.

This result may change, however, if ThirdDE is regarded as non-fiscally transparent under the laws of the other Contracting State. Assuming that ThirdDE is treated as non-fiscally transparent by the other Contracting State, the income will not be treated as derived by a resident of the other Contracting State for purposes of the Convention. However, ThirdDE may still be entitled to the benefits of the U.S. tax treaty, if any, with its country of residence. In the case of hybrid entities (that is, an entity that is treated as fiscally transparent under the laws of one State and non-fiscally transparent under the laws of the other, or of a third State), it may be that the person who “derives” the income under Article 1(6) is not the same person as the “beneficial owner” under Article 10 . This will not prevent a claim for treaty benefits, so long as each of the requirements is met by one or more residents of the other Contracting State. For example, assume the same facts, except that the intermediate entity is SubDE, an entity organized in the other Contracting State, but treated as a disregarded entity for U.S. tax purposes. Paragraph 2(a) provides that the reduced withholding rate is available to a company that is the beneficial owner of the dividend and, which owns, directly, at least 10 percent of the shares of USCo. Under the laws of the other Contracting State, SubDE is taxable as a corporation. Accordingly, the dividend is treated as derived by a resident of the other Contracting State, SubDE, under the rules of Article 1(6) . From the U.S. perspective, SubDE does not exist as a separate entity. Accordingly, the combined entity that is SubDE and PCo satisfy the requirements that the beneficial owner be a resident of the other Contracting State and that the shares of USCo be held directly. In addition, the analysis and result are unchanged if all of the outstanding shares in SubDE are owned by an individual who is a resident of the other Contracting State.

From the U.S. perspective, SubDE does not exist as a separate entity. Accordingly, the combined entity that is SubDE and PCo satisfy the requirements that the beneficial owner be a resident of the other Contracting State and that the shares of USCo be held directly. In addition, the analysis and result are unchanged if all of the outstanding shares in SubDE are owned by an individual who is a resident of the other Contracting State

lethal wrote:

jeff2sf wrote:jeez-us andy, i'm fighting with like 97 people on this board, we can't be fighting too. I just saw a lot of negatives in your posts and busted your balls about it. I've never run into a triple negative by an intelligent person before.

This is just something I had to work on this morning, for example. I spend days reading stuff like this exerpt from the US-UK Double Tax Treaty. You can imagine why I write the way I do. Either that, or I'm just not intelligent.

This result may change, however, if ThirdDE is regarded as non-fiscally transparent under the laws of the other Contracting State. Assuming that ThirdDE is treated as non-fiscally transparent by the other Contracting State, the income will not be treated as derived by a resident of the other Contracting State for purposes of the Convention. However, ThirdDE may still be entitled to the benefits of the U.S. tax treaty, if any, with its country of residence. In the case of hybrid entities (that is, an entity that is treated as fiscally transparent under the laws of one State and non-fiscally transparent under the laws of the other, or of a third State), it may be that the person who “derives” the income under Article 1(6) is not the same person as the “beneficial owner” under Article 10 . This will not prevent a claim for treaty benefits, so long as each of the requirements is met by one or more residents of the other Contracting State. For example, assume the same facts, except that the intermediate entity is SubDE, an entity organized in the other Contracting State, but treated as a disregarded entity for U.S. tax purposes. Paragraph 2(a) provides that the reduced withholding rate is available to a company that is the beneficial owner of the dividend and, which owns, directly, at least 10 percent of the shares of USCo. Under the laws of the other Contracting State, SubDE is taxable as a corporation. Accordingly, the dividend is treated as derived by a resident of the other Contracting State, SubDE, under the rules of Article 1(6) . From the U.S. perspective, SubDE does not exist as a separate entity. Accordingly, the combined entity that is SubDE and PCo satisfy the requirements that the beneficial owner be a resident of the other Contracting State and that the shares of USCo be held directly. In addition, the analysis and result are unchanged if all of the outstanding shares in SubDE are owned by an individual who is a resident of the other Contracting State.

From the U.S. perspective, SubDE does not exist as a separate entity. Accordingly, the combined entity that is SubDE and PCo satisfy the requirements that the beneficial owner be a resident of the other Contracting State and that the shares of USCo be held directly. In addition, the analysis and result are unchanged if all of the outstanding shares in SubDE are owned by an individual who is a resident of the other Contracting State

SK790 wrote:Going to PORTLAND today. Pray for me.

SK790 wrote:Going to PORTLAND today. Pray for me.