The Internal Revenue Service (IRS) has released the text of a private letter ruling (PLR) on 3 June 2005 holding that stock of a US corporation owned by a UK company through foreign entities that elect to be treated as disregarded entities under the US check-the-box regulations can qualify for the zero dividend withholding rate under

Art. 10(3) of the 2001 United States-United Kingdom income tax treaty. Art. 10(3)(a) of the US-UK treaty provides that dividends are exempt from tax in the source contracting state if the beneficial owner is a company resident in the other contracting state that has owned shares representing 80% or more of the voting power of the company paying the dividends for a 12-month period ending on the date the dividends are declared and certain other requirements are met. The Treasury Department Techn…