United States Tax News
Protocol to treaty between Luxembourg and United States – details
Protocol to treaty between France and United States submitted for ratification
Treaty between United States and Hungary – negotiations
Protocol to treaty between Switzerland and United States initialed
RS issues industry directive regarding Section 965 dividend received deduction and Section 482 transfer pricing adjustments
IRS releases updated version of Publication 901 on US income tax treaties
Protocol to treaty between Luxembourg and United States signed
US
Switzerland
IRS issues updated Publication 515 for withholding of tax on non-resident aliens and foreign entities
US economic stimulus bill: business provisions
Protocol and MoU to treaty between United States and France signed – details
Treaty between United States and Malta referred to US Congress for ratification
Memorandum of Understanding signed between US and German competent authorities
Protocol between United States and Canada enters into force
Final regulations issued to add Bulgarian Aktsionerno Druzhestvo to US check-the-box per se corporation list
Treaty and protocol between United States and Bulgaria enter into force
Protocol to treaty between New Zealand and United States – details
Treaty between United States and Iceland enters into force
Treaty between India and US (non-discrimination) – Indian decision on applicability of withholding tax on lease rentals paid to non-residents and deductibility of such payments for Indian tax purposes
Treaty between Australia and United States – ATO rules payments for hire of substantial equipment not subject to withholding tax
Protocol to treaty between United States and Canada ratified
Treaty between United States and Iceland ratified
IRS extends relief period for investments by CFCs in US debt obligations
US-Bulgaria income tax treaty and protocol ratified by US
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
2001 treaty between United States and United Kingdom – IRS issues interpretation of Art. 18 (Pension Schemes)
OECD released 2008 Model Tax Convention
Fifth protocol to treaty between US and Canada – US Technical Explanation published
Treaty between US and Bulgaria – US Technical Explanation published
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