The Competent Authorities of Ireland and the United States have entered into an agreement concerning the treatment of Common Contractual Funds (CCF) under the Ireland-US tax treaty of 28 July 1997. The agreement was entered into at the request of Ireland in order to clarify the transparent nature of the CCF and in order to preserve the entitlement to benefits under the Convention of Irish resident unit holders in a CCF.
Specifically, it had come to the attention of the Competent A…