Introduction -- Beneficial Ownership : From Conscience to Liberalism and Law -- Beneficial Ownership in Tax Law -- From Domestic Tax Law to Tax Treaties : How Beneficial Ownership Jumped -- from US and UK Tax Treaty Policy into the Worldwide Tax Treaty Network -- Changing Skin in the OECD Model...

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...