BDO USA has published an article, “U.S. and UK Competent Authorities Sign Arrangements Providing Guidance on Certain Terms in the U.S.-UK Tax Treaty”, published on BDO USA. The abstract is as follows:
On July 26, 2021, the U.S. and UK competent authorities signed two arrangements that address the definition of “equivalent beneficiary” for purposes of the 2001 income tax treaty (as amended by the Protocol signed July 2002). One of the arrangements clarifies the treatment of the UK as a member of the European Community following its withdrawal from the EU (“EU Arrangement”). The other arrangement clarifies the treatment of the U.S.-Mexico-Canada Agreement (USMCA) now that it supersedes the North American Fair Trade Agreement (NAFTA) (“USMCA Arrangement”).
Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.