The Supreme Court Decision in the Government Pension Investment Fund Case: A Tale of Transparency and Beneficial Ownership (in Plato’s Cave)

Journal
Gusmeroli, M.
Italy
Bulletin for International Taxation 2010 (Volume 64), No. 4
PriceUSD 45

This article addresses a Supreme Court case involving a Japanese pension fund investing in Italy via a US partnership managed by a Japanese bank. It is held that, without a beneficial ownership clause, there can be no attribution of income paid to a transparent entity to a participant or of income paid to an agent to the principal.