Anti-treaty shopping restrictions in the new U.S.-Netherlands tax treaty. Tax Executive | September 1, 1993| | COPYRIGHT 1993 Tax Executives Institute, Inc. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan.  All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information) Copyright

Introduction

The recently negotiated income tax treaty between the United States and the Netherlands [hereinafter Netherlands-2 Treaty] (1*) and accompanying protocol [hereinafter Netherlands-2 Protocol](2) contain a series of detailed anti-treaty shopping rules that have hitherto been absent in U.S. bilateral tax treaties. Intended primarily to update the antiquated U.S.Netherlands Treaty of 1948 [hereinafter Netherlands-l Treaty],(3) the new treaty represents the U.S. Treasury Department's most successful effort at extending into actual treaty formation extant ...

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