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Of the category “any other person resident in the United States for purposes of its tax,” the meaning of “a person acting as a partner” as stipulated in the proviso of Article 3(1)(b)(ii) of the Convention between the Republic of Korea and the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and the Encouragement of International Trade and Investment (“Korea-U.S. Tax Treaty”) / The meaning of “only to the extent that the income derived by such person is subject to United States tax as the income of a resident” as provided in Article 3(1)(b)(ii) of the Korea-U.S. Tax Treaty / The scope of applicability of the Korea-U.S. Tax Treaty to a U.S. entity as a resident of the United States, where it is not liable for U.S. tax, even though the entity derived income in Korea as a foreign corporation
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