To take advantage of the favorable provisions of an income tax treaty with a limitation on benefits provision: 

 A. The taxpayer of a non-treaty country must form a corporation in one of the treaty countries to conduct business in the other treaty country. 

B. The taxpayer must receive only investment income from a treaty country 

C. The Taxpayer must be an individual since Corporations do not qualify for preferential treaty rates 

D. The taxpayer must be a resident of one of the treaty countries

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