United States Tax News
New agreement on organizations eligible for benefits under Art. 35 of Netherlands-US treaty signed
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
US
Indian Supreme Court decision on whether captive BPO activities give rise to PE and income attributable to PE on such activities
Final regulations issued for determination of earnings and profits attributable to stock of CFCs
US Senate hearings on protocol to treaty between Germany and US
US Senate hearings on protocol to treaty between Denmark and US
Belgian abolition of fixed FTC incompatible with tax treaty between Belgium and US
US Senate hearings on new treaty and protocol between Belgium and US
Treasury Department reissues list of international boycott countries that result in restriction of US tax benefits
German Lower Court
US Senate hearings on protocol to treaty between Finland and US
Non-discrimination and group income elections
Treasury Department released statement on attribution of profits under Authorized OECD Approach (AOA)
US court orders IRS summons enforced under US-Mexico income tax treaty
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Italian tax authorities interpret application of Art. 15 of EU-Swiss Agreement
Treaty between Belgium and US ratified
Treaty between Australia and United States – US tax debts not enforceable in
Final regulations issued on US withholding exemption for portfolio interest received by foreign persons
Tax treaty between Australia and United States – Australia's Federal Court rejects tax treaty override
Revised Commentary on Article 7 of OECD Model released
Proposed regulations issued to curb foreign tax credit abuses
IRS issues fact sheet on reporting requirements for foreign financial accounts
US
Treaty between United States and Bulgaria signed
Indian ruling on classification of income of Canadian and US foreign institutional investors making portfolio investments in India
Final Report on Improving the Resolution of Tax Treaty Disputes
Treaty between United States and Japan – US court dismisses claims for relief for information exchanged under treaty
Treasury Department reissues list of international boycott countries that result in restriction of US tax benefits
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