India: Fiscally transparency U.S. entity qualifies as U.S. resident eligible for treaty benefits (Tribunal decision)

A Tribunal decision concerning whether a U.S. limited liability corporation qualified as a U.S. resident eligible for treaty benefits under the U.S.-India income tax treaty.

The Delhi bench of the Tribunal held that a U.S. limited liability corporation (LLC) qualified as a U.S. resident eligible for treaty benefits under the U.S.-India income tax treaty because even though the LLC was fiscally transparent, its income was subject to U.S. tax in the hands of its owner, a U.S. corporation.

The case is: General Motors Company USA v. ACIT

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India: Fiscally transparency U.S. entity qualifies as U.S. resident eligible for treaty benefits (Tribunal decision)

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