United States Tax News
Report on Attribution of Profits to PEs released
Supreme Court of Thailand treats payment for US customer base as royalty
China signs first APA with US
New treaty between Belgium and US signed
Treaties with the United States and Canada considered
Indian decision finds payments for use of satellite transponder not "royalty"
Protocol to treaty between Denmark and US
IRS updates list of treaty countries with corporations qualified to pay dividends eligible for reduced US tax rates
Thailand
UK–US treaty agreement on dual consolidated losses
Treaty between Iceland and United States – negotiations concluded
New protocol to France-US income tax treaty ratified
Exchange of information treaty between US and Isle of Man enters into force
Ruling on taxability of non-resident with captive BPOs to be appealed
Proposed regulations issued on exclusion of previously taxed income of controlled foreign corporations
IRS announces new user fee for issuing US residency certificates
Protocol to treaty between Finland and United States presented to Finnish parliament
Regulations issued on tax treatment of foreign persons from residual interests in US REMICs
Tax treaty between Italy and US – Italian ruling on concept of beneficial owner (royalties)
Protocol amending treaty between US and Sweden enters into force
Proposed regulations issued on taxpayers eligible to claim US foreign tax credit
US
New US model tax treaty expected in 2006
Exchange of information agreement between Isle of Man and US – implementation
US Senate may hold hearings on new Denmark, Finland, and Germany protocols
Indian decision on applicability of tax treaty or domestic tax rate for different income streams
Australian treatment of shipping and aircraft leasing profits of UK and US enterprises
US Treasury Department announces signing of protocol to US-Germany income tax treaty
Australian Taxation Office denies interest withholding tax exemption to US financial institution
Proposed regulations issued for determination of earnings and profits attributable to stock of CFCs under IRC Sec. 1248
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