Avoiding US WHT on dividends via CY residency

[Onassis]

Could an entity that is beneficially owned by a CY tax resident claim US-CY tax treaty benefits if it's not actually registered for corporate tax in Cyprus?

To rephrase, I would like to hold US equities in a private foundation while being a non-dom tax resident of Cyprus. As I would be the sole beneficial owner of the foundation I am wondering if it would be possible to reduce the WHT on dividends to 15% based on the US-CY tax treaty.

Thanks.

 

[Marzio]

From what i understand if you hold US equities in your name you could reduce WHT on dividends to 15% and be tax exempt in CY.

If you interpose an entity like a foundation between you and US equities the foundation could be assimilable to a trust and to be considered CY resident it has to be subject to tax.