Partial Residence Clauses in US Treaty Practice

Journal
Brabazon, M.L.
United States
Bulletin for International Taxation 2020 (Volume 74), No. 8
FormatPDF
USD
45

Partial residence clauses were a standard feature of pre-1996 US tax treaties. Many remain in force today. This article considers their history, design and judicial interpretation, their relationship with the transparent entity clause in current US and OECD Models and the OECD Partnership Report, and their influence on treaty interpretation.