United States Tax News
US Court of Appeals affirms retrospective global interest netting for tax underpayments and tax overpayments
Treaty between US and Canada – IRS releases competent authority agreement regarding application of Authorized OECD Approach (AOA)
Final regulations issued on treatment of overall foreign and domestic losses (OFLs and ODLs) for FTC limitation
Relief provided under PFIC rules for foreign banks holding government bonds
Proposed regulations issued on high-taxed passive income and OFL recapture for FTC limitation
Treaty between India and United States – Indian decision on the sale of copyrighted software is not in the nature of royalties
Final regulations issued on surrogate foreign corporations in offshore inversion transactions
Foreign entity's advance to its US subsidiary characterized as loan
IRS issues drafts of revised withholding certificates for foreign beneficial owners
US Court of Appeals allows FTC for UK windfall tax
Regulations issued on substantial business activities in offshore inversion transactions
US Court of Federal Claims: position of taxpayer upheld under FSC regime
Regulations issued regarding upfront payments made by CFC under NPC
US taxpayer's investment in foreign entity re-characterized as loan
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
2012 Budget – President submits to Congress
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Treaty between Malta and United States enters into force
Protocol to treaty between New Zealand and United States enters into force
US Congress enacts FTC and other international tax reforms
Treaty between Spain and US – Spanish National Court holds payments for software subject to 10% withholding tax (general rate for "other royalties")
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Treaty between Chile and United States – details
2011 Budget – President submits to Congress
Protocol to treaty between United States and France enters into force
Treaty between Italy and US enters into force
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Protocol to treaty between Switzerland and United States – details
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Protocol to treaty between US and New Zealand referred to US Senate
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