Article 4

Barbados remittance-based taxpayer is a Treaty resident under Crown Forest test

habitual abode determined in context based inter alia on relative stays and nature of activities

a Singapore corporation was a resident there for Treaty purposes – even though it was subject to tax on a territorial basis - provided its CMC was there

a company resident under Luxembourg domestic law (its legal seat was there), and that was “liable to be liable to tax,” was resident there for Treaty purposes even though a conduit

a deemed US resident was not a US treaty resident

meaning of “substantially all” in UAE Convention informed by its meaning under ITA

Dutch legal expert testimony was required in order to establish dual corporate residency - and failure to engage competent authorities

where Canco is held by fiscally transparent Franceco, which is held by LP with only some US partners, there is a choice as to which Treaty to apply

an individual had his centre of vital interest where he was employed, rather than where he had his greater personal ties