Is the UTPR a 100 Percent Tax on a Deemed Distribution?
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Is the UTPR a 100 Percent Tax on a Deemed Distribution?
Fadi Shaheen floats the proposition that from a U.S. tax perspective, the UTPR is the mathematical, conceptual, and legal equivalent of a 100 percent withholding tax on a deemed distribution by the UTPR entity, and he addresses questions that would follow regarding the desirability of such a confiscatory tax and its interaction with tax treaties.
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