2024-12-06
Yesterday the IRS uploaded two new documents to its website:
I had not seen these Technical Explanations before. It is helpful for the IRS to publish some of these hard-to-find documents.
In addition, on Monday the IRS published a Competent Authority Arrangement between the U.S. and Norway providing that Article 20 of the treaty, limiting treaty benefits for investment or holding companies, is not applicable to U.S. regulated investment companies (as defined in Code §851).