United States Tax News
Discussion draft on New Art. 7 of OECD Model – details
Treaty between India and US – Indian ruling that monthly payments for bandwidth charges treated as business profits, not royalty or fees for included services
Treaty between US and Iceland – US Technical Explanation published
Treaty between United States and Malta - details
Protocol to treaty between Bulgaria and US ratified
On 10 July 2008, the Minister of Finance indicated Canada's agreement with the US Treasury Department's technical explanation to the fifth protocol to the Canada-US tax treaty. Canada ratified the protocol on 14 December 2007, when Bill S-2 received Royal Assent.
Treaty between Germany and United States – German Federal Financial Court rules on non-deductibility of losses from US (non-EU/EEA) PE
OECD Council approves 2008 Model Tax Convention
Final regulations issued to curb FTC abuses
Comments on draft contents of 2008 update to Model Tax Convention published
Final regulations regarding partnership allocations to look-through entities or members of consolidated group
Bulgarian Income Tax Treaty and Protocol referred to US Senate
Tax treaty between Canada and US – US Tax Court rules AMT FTC limitation prevails over treaty
Protocol to treaty between US and Germany – IRS issues interim guidance re mandatory arbitration procedure
Treaty between United States and Malta initialled
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
US announces negotiations for new protocol with New Zealand
Treaty between US and Iceland – referred to US Senate Committee on Foreign Relations
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Treaty between Australia and US – No treaty relief for US tax paid
US check-the-box regulations updated to add Bulgarian entity to per se corporation list
IRS issues Chief Counsel Advice on recapture of dual consolidated losses
Indian decision on software licensing
Protocol to US-Canada treaty referred to US Senate Committee on Foreign Relations
Protocol to treaty between US and Canada transmitted to US Senate for consent to ratify
Treaty between US and Malta – negotiations
Treaty between US and Bulgaria – details
IRS publishes Chief Counsel Advice on reasonable cause requests with respect to dual consolidated losses
Protocol to treaty between Bulgaria and US signed
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