United States Tax News
US Tax Court reclassifies loan structure as dividend payments
24 June 2013
2014 Budget – President submits Administration's proposals to Congress with international tax changes
24 June 2013
Tax benefits from structured financial transaction denied for lack of economic substance
24 June 2013
Indian decision that arm's length adjustment is allowable for advertisement and marketing expenses
24 June 2013
Regulations issued on property transfers and stock distributions in cross-border reorganizations
24 June 2013
2014 Budget – President submits Administration's proposals to Congress with tax changes for businesses
24 June 2013
US Federal Court of Appeals affirms denial of loss deduction for lack of economic substance
24 June 2013
Treaty between India and United States – Indian decision that transfer of shares without consideration is not prima facie a tax avoidance scheme
24 June 2013
Treaty between US and Switzerland – image right payments are exempt from US tax as royalties
24 June 2013
India-US tax treaty and India-Ireland tax treaty – Indian decision that a website does not by itself constitute a PE
24 June 2013
Swiss bank sentenced for US tax evasion schemes
6 May 2013
Indian decision on source of royalty paid between non-resident companies
6 May 2013
Treaty between United States and Poland – signing announced and details
4 May 2013
Treaty between US and Norway – IRS releases competent authority agreement regarding fiscally transparent entities
4 May 2013
Treaty between India and United States – Indian decision that taxability of business income on presumptive basis is subject to presence of PE
4 May 2013
Treaty between Belgium and United States – clarifying circular published
4 May 2013
Treaty between United States and Spain – text of protocol and MOU released
25 March 2013
American Taxpayer Relief Act signed into law
25 March 2013
Swiss bank enters guilty plea for US tax evasion schemes
25 March 2013
Final regulations issued to prevent tax-avoidance in stock acquisitions by related corporations
25 March 2013
US UPREIT is a capture foreign collective investment vehicle
25 March 2013
Legislation enacted to avert fiscal cliff
25 March 2013
Treaty between United States and Japan – texts of protocol and exchange of notes released
25 March 2013
IRS Chief Counsel issues memorandum on electronic submission of withholding certificates
9 February 2013
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
9 February 2013
IRS Chief Counsel issues memorandum on ETI exclusion for purposes of subpart F income
2 December 2012
Public comments requested on FIRPTA tax incident to corporate reorganizations and distributions
2 December 2012
Public comments requested on IRS forms for transfers of US real property under FIRPTA
2 December 2012
Public comments requested on US foreign tax credit treatment of certain foreign dividends
2 December 2012
Netherlands to sign agreement with the US with respect to FATCA
2 December 2012