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http://citizenshipsolutions.ca/2019/03/25/article-4-paragraph-2-of-the-us-uk-tax-treaty-a-clause-preventing-the-use-of-the-tax-treaty-tie-breaker-for-some-green-card-holders/
Article 4 paragraph 2 of the U.S. U.K. Tax Treaty: A clause preventing the use of the tax treaty tie breaker for some Green Card holders