Extract to table

The Chapter 11 alternative offers a materially more favorable CODI outcome for TAI through the unlimited bankruptcy exclusion under IRC Section 108(a)(1)(A), but this benefit must be weighed against estimated administrative costs of $18

In addition, the Treaty's limitation on benefits ("LOB") provisions must be assessed to confirm that TSL and KFO qualify as Treaty-eligible residents of Greece entitled to claim reduced withholding rates

shareholder whose tax position must be separately analyzed

The applicable Treaty rate must be determined by reference to the specific provisions of Article 11, including any limitations on the categories of interest eligible for the reduced rate

For purposes of claiming Treaty benefits, TSL must qualify as a "resident" of Greece under Article 4 of the Treaty

TSL must also satisfy the Treaty's LOB provisions to be eligible for the reduced withholding rate on interest