United States Tax News
Treaty between India and United States – Indian decision that transfer of shares without consideration is not prima facie a tax avoidance scheme
Treaty between US and Switzerland – image right payments are exempt from US tax as royalties
India-US tax treaty and India-Ireland tax treaty – Indian decision that a website does not by itself constitute a PE
Swiss bank sentenced for US tax evasion schemes
Indian decision on source of royalty paid between non-resident companies
Treaty between United States and Poland – signing announced and details
Treaty between US and Norway – IRS releases competent authority agreement regarding fiscally transparent entities
Treaty between India and United States – Indian decision that taxability of business income on presumptive basis is subject to presence of PE
Treaty between Belgium and United States – clarifying circular published
Treaty between United States and Spain – text of protocol and MOU released
American Taxpayer Relief Act signed into law
Swiss bank enters guilty plea for US tax evasion schemes
Final regulations issued to prevent tax-avoidance in stock acquisitions by related corporations
US UPREIT is a capture foreign collective investment vehicle
Legislation enacted to avert fiscal cliff
Treaty between United States and Japan – texts of protocol and exchange of notes released
IRS Chief Counsel issues memorandum on electronic submission of withholding certificates
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
IRS Chief Counsel issues memorandum on ETI exclusion for purposes of subpart F income
Public comments requested on FIRPTA tax incident to corporate reorganizations and distributions
Public comments requested on IRS forms for transfers of US real property under FIRPTA
Public comments requested on US foreign tax credit treatment of certain foreign dividends
Netherlands to sign agreement with the US with respect to FATCA
Transactions with foreign corporations reduce possessions tax credit
US Court of Appeals for Fifth Circuit requires disclosure of foreign accounts under Bank Secrecy Act
Advance agreements between related parties properly characterized as equity
UK-US FATCA agreement signed
Regulations issued on integrated hedging transactions
Temporary regulations issued regarding payment of dividend equivalents from US sources
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
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