The competent authorities of the United States and Spain have entered a mutual agreement on the treatment of limited liability companies (LLCs), disregarded entities, and Subchapter S corporations under the income tax treaty and protocol signed by the two countries on 22 September 1990.
The agreement provides that the phrase "any other body of persons" as used in the definition of "person" in Art. 3(1)(d) of the treaty, which is further defined in Para. 4 of the protoco…