Announcement 2024-42: U.S.-Norway competent authority arrangement regarding regulated investment companies
Competent authorities agree that Article 20 (investment or holding companies) is not applicable to regulated investment companies
The IRS today issued Announcement 2024-42 to notify taxpayers that the competent authorities of the United States and Norway entered a competent authority arrangement (CAA) under paragraph 2 of Article 27 (mutual agreement procedure (MAP)) of the U.S.-Norway income tax treaty, in which the competent authorities confirm that Article 20 (investment or holding companies) is not applicable to a U.S. investment company that qualifies as a regulated investment company (RIC) pursuant to sections 851 and 852.