United States Tax News
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
US Senate Finance Committee releases proposals for international business tax reform
US Senate Finance Committee releases proposals for cost recovery and tax accounting rules
US Tax Court denies tax deduction for qualified domestic production activities with regard to direct mail advertising
Treaty between United States and Mexico – US District Court denies summary judgment with regard to residence of dual resident taxpayer
IRS issues Memorandum on cross-border reorganization transactions
Treaty between India and United States – Indian decision that similar business activities do not give rise to a PE
US Tax Court allows interest deduction for loan that was part of transaction lacking economic substance
US Tax Court reduces deductible amount of repatriated CFC earnings based on transfer pricing adjustments
Proposed regulations issued regarding limitations on loss importation
Treaty between India and United States – Indian decision on attribution of profits arising from services rendered to head office
White House issues proposals for simplifying tax code and creating jobs and economic growth
US Tax Court disallows tax benefits from cross-border leasing transactions
Treaty between US and Belgium – IRS releases text of competent authority agreement on application of AOA
Treaty between India and United States – Indian decision on when fixed place is "at the disposal" of the non-resident company and the manner of computing profits attributable to a PE
Treaty between Russia and US – Russian MoF clarifies tax treatment applicable to interest that may qualify as dividends
1970 Treaty between Belgium and US – Belgian Supreme Court decides that reduction of tax credit for foreign interest by multiplication with a debt financing coefficient is compatible with treaty
US Court of Appeals disallows favourable dividend treatment for Subpart F income
Decision that internal TNMM is preferred over external TNMM
Treaty between Australia and United States – Australian Federal Court holds Cayman Islands partnership not US resident and cannot be assessed under the treaty
US Senate Finance Committee issues paper on international tax reform options
US, Australia, and UK announce plan to share data to combat offshore tax evasion
US Tax Court reclassifies loan structure as dividend payments
Multilateral action between United Kingdom, France, Germany, Italy and Spain to counter tax evasion
2014 Budget – President submits Administration's proposals to Congress with international tax changes
Tax benefits from structured financial transaction denied for lack of economic substance
Indian decision that arm's length adjustment is allowable for advertisement and marketing expenses
Regulations issued on property transfers and stock distributions in cross-border reorganizations
2014 Budget – President submits Administration's proposals to Congress with tax changes for businesses
US Federal Court of Appeals affirms denial of loss deduction for lack of economic substance
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