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United States Tax News

U.S. Issues Final Anti-Inversion Regulations
Jul 13, 2018
Ukraine Clarifies Acceptable Residence Certification for Reduced Withholding Tax Rates Under Tax Treaty with the U.S.
Jul 13, 2018
U.S. IRS Publishes CbC Exchange Arrangement with Indonesia
Jul 12, 2018
U.S. IRS Publishes Joint Statement with Germany on Spontaneous Exchange of CbC Reports
Jul 11, 2018
Indian Tribunal Holds Franchise in India Does Not Constitute PE under Tax Treaty with the U.S.
Jul 10, 2018
U.S. IRS Issues Transfer Pricing Examination Process Guide
Jul 09, 2018
U.S. IRS Publishes Draft Form 1040 for 2018
Jul 06, 2018
U.S. IRS Announces Five Additional Large Business and International Compliance Campaigns
Jul 05, 2018
U.S. Signs CbC Exchange Arrangement with Indonesia
Jun 29, 2018
SSA between Brazil and the U.S. to Enter into Force
Jun 28, 2018
U.S. House Budget Committee Approves FY 2019 Budget Resolution
Jun 25, 2018
U.S. Supreme Court Holds Physical Presence Not Required for Collection of Online Sales Tax by States
Jun 22, 2018
U.S. Publishes CbC Exchange Arrangement with Slovenia
Jun 18, 2018
U.S. IRS Provides Additional Delay for Final and Temporary Regs on Foreign Currency Gains/Losses
Jun 14, 2018
G7 Summit Communiqué Published Including Commitment to Fair Taxation in the Digital Economy
Jun 13, 2018
U.S. Interest Rates on Overpaid and Underpaid Tax Unchanged for Q3 2018
Jun 13, 2018
Draft Bill Introduced in U.S. House of Representatives to Amend CFC/GILTI Rules
Jun 11, 2018
U.S. Senators Introduce Legislation to Require Congressional Approval of National Security-Designated Tariffs
Jun 08, 2018
U.S. Signs CbC Exchange Arrangement with Slovenia
Jun 08, 2018
U.S. IRS Updates Q&A on Reporting Related to Section 965 Transition Tax on 2017 Tax Returns
Jun 06, 2018
U.S. Steel and Aluminum Tariffs Implemented on Imports from Canada, Mexico, and the EU
Jun 04, 2018
Croatia and the U.S. to Continue Tax Treaty Negotiations
Jun 01, 2018
U.S. Publishes CbC Exchange Arrangement with Liechtenstein
May 31, 2018
Brazil Senate Approves Pending SSA with the U.S.
May 25, 2018
Senate Bill Introduced to Protect U.S. Technology, Intellectual Property, and Industry from China
May 24, 2018
U.S. Treasury List of International Boycott Countries Published
May 23, 2018
CbC Exchange Arrangement between Greece and U.S. Has Become Operative
May 23, 2018
U.S. IRS Announces New APA Template
May 22, 2018
Apple Makes First Payment for Ireland State Aid; EU Court Holds U.S. May Not Intervene in Pending Appeal
May 21, 2018
U.S. IRS Issues CbC Reporting News & Information Issue 2018-3
May 21, 2018
SSA between Slovenia and the U.S. Transmitted to U.S. Congress
May 21, 2018
U.S. Signs CbC Exchange Arrangement with Mauritius
May 17, 2018
U.S. IRS Releases Practice Units on Disposition of Nonfunctional Currency and Determination of Qualified R&D Expenses Based on GAAP ASC 730 Reporting
May 16, 2018
U.S. Signs CbC Exchange Arrangement with Liechtenstein
May 15, 2018
U.S. IRS Releases Practice Units on Losses Claimed in Excess of Basis in an S Corp and Qualification for Advanced Energy Project Credit
May 03, 2018
U.S. Consultation on Recommendations for 2018-2019 Priority Guidance Plan
May 02, 2018
U.S. IRS Publishes MoU with Indonesia for No Local Filing and Provides Operative Date for CbC Exchange Arrangement with Estonia
Apr 27, 2018
Apple to begin Repayment of Illegal State Aid to Ireland
Apr 26, 2018
Greek Parliament Approves Ratification of Arrangement for Exchange of CbC Reports with the U.S.
Apr 25, 2018
New TIEA between Costa Rica and the U.S. Signed
Apr 25, 2018
U.S. Negotiating CbC Exchange Arrangement with Austria
Apr 20, 2018
U.S IRS Releases Practice Unit on Exhaustion of Administrative Remedies for Foreign Tax Credit
Apr 19, 2018
U.S. Negotiating CbC Exchange Arrangement with Indonesia
Apr 19, 2018
U.S. IRS Announces Updated Inflation Adjustments for 2018
Apr 18, 2018
U.S. IRS Releases Practice Units on General Deductions of a Foreign Corporation, Reduced Taxes under a Treaty, and Statute of Limitations on Assessments
Apr 17, 2018
U.S. IRS Updates Q&A on Reporting Related to Section 965 Transition Tax on 2017 Tax Returns
Apr 16, 2018
U.S. IRS Issues Publication 5292 on How to Calculate Section 965 Amounts and Elections Available to Taxpayers
Apr 12, 2018
U.S. IRS Issues Updated FAQ and Guidance on CbC Reporting
Apr 11, 2018
U.S. IRS Publishes Guidance on Transition Tax, Business Interest Expense Limitation, and Withholding on Transfer of Partnership Interests
Apr 04, 2018
U.S. IRS Issues Notice on Amendments to CbC Reporting Regulations for National Security Contractors
Apr 02, 2018
U.S. IRS Publishes "Dirty Dozen" List of Tax Scams for 2018
Mar 26, 2018
U.S. Provides Temporary Suspension of Steel and Aluminum Tariffs for the EU, Argentina, Australia, Brazil, and South Korea
Mar 23, 2018
U.S. Publishes CbC Exchange Arrangement with the Cayman Islands
Mar 23, 2018
G20 Finance Ministers Communiqué Published following Buenos Aires Meeting
Mar 22, 2018
SSA between the U.S. and Uruguay Transmitted to U.S. Congress
Mar 22, 2018
U.S. Product Exclusion Procedures Published for Upcoming Steel and Aluminum Tariffs
Mar 21, 2018
Draft Legislation to Ratify Arrangement for Exchange of CbC Reports with U.S. Submitted to Greek Parliament
Mar 21, 2018
IRS Announces Five Additional Large Business and International Compliance Campaigns
Mar 20, 2018
Liechtenstein Looking to Negotiate Tax Treaty with the U.S.
Mar 19, 2018
U.S. IRS Publishes Q&A on Reporting Related to Section 965 Transition Tax on 2017 Tax Returns
Mar 15, 2018
U.S. Signs CbC Exchange Arrangement with the Cayman Islands
Mar 15, 2018
IRS Releases Practice Unit on Valid Shareholder Debt Owed by S Corporation
Mar 13, 2018
Brazil Chamber of Deputies Approves Pending SSA with the U.S.
Mar 12, 2018
U.S. Interest Rates Increase on Overpaid and Underpaid Tax for Q2 2018
Mar 09, 2018
Bill Submitted to U.S. Congress to Counter Certain Aspects of the Tax Cuts and Jobs Act
Mar 08, 2018
IRS Releases Practice Unit on Functional Currency of a QBU
Mar 02, 2018
European Commission Publishes Non-Confidential Version of Decision that Luxembourg Granted Illegal State Aid to Amazon
Feb 28, 2018
U.S. Negotiating CbC Exchange Arrangement with the Cayman Islands
Feb 28, 2018
SSA between Paraguay and the U.S. under Negotiation
Feb 23, 2018
U.S. Proposed Rule on Eliminating Unnecessary Tax Regulations
Feb 16, 2018
IRS Releases Practice Unit on Definition of Foreign Personal Holding Company Income and Common Exceptions
Feb 16, 2018
IRS Issues Guidance on Changes in Accounting Periods Related to the Transition Tax
Feb 15, 2018
Second Quarter Update to U.S. 2017-2018 Priority Guidance Plan Issued
Feb 14, 2018
U.S. Joint Committee on Taxation Publishes Overview of Federal Tax System for 2018
Feb 13, 2018
U.S. Negotiating CbC Exchange Arrangement with Croatia
Feb 12, 2018
U.S. IRS Increases User Fees for APAs
Feb 09, 2018
IRS Releases Practice Unit on Adjustments to Debt Basis for S Corporations
Feb 08, 2018
U.S. to Negotiate Tax Treaty with Armenia
Feb 08, 2018
U.S. Supreme Court Agrees to Hear Case on Economic Nexus Law
Feb 07, 2018
Switzerland Ranked Number 1 in Financial Secrecy; U.S. Ranked Number 2
Feb 01, 2018
Dutch Tax Treaty Negotiation Plans for 2018
Feb 01, 2018
U.S. IRS Issues Revenue Procedure on Safe Harbor Methods for Continuity of Interest Determination for Tax-Free Reorganizations
Jan 30, 2018
International Compliance Assurance Programme Pilot for Transfer Pricing Launched
Jan 25, 2018
IMF Updates World Economic Outlook with Impact of U.S. Tax Reform
Jan 25, 2018
U.S. IRS Issues Additional Guidance on Transition Tax on Foreign Earnings
Jan 22, 2018
U.S. IRS Issues Guidance Update on CbC Reporting
Jan 19, 2018
India and U.S. Sign First Bilateral APA
Jan 19, 2018
U.S. IRS LB&I Division Memos Published with New Instructions for Transfer Pricing Examinations
Jan 18, 2018
IRS Releases Practice Unit on Stock Basis Ordering Rules and Self-Employment Tax in U.S. Territories
Jan 16, 2018
U.S. Publishes CbC Exchange Arrangement with Poland
Jan 16, 2018
U.S. Joint Committee on Taxation Publishes List of Expiring Federal Tax Provisions
Jan 12, 2018
U.S. Publishes CbC Exchange Arrangement with Bermuda
Jan 12, 2018
U.S. Treasury List of International Boycott Countries Published
Jan 10, 2018
Taiwan Looking to Negotiate Tax Treaty with the U.S.
Jan 09, 2018
IRS Releases Practice Unit on Substantial Contribution Test for CFC Manufacturing Exception
Jan 05, 2018
U.S. Signs CbC Exchange Arrangement with Poland, Confirms Signature Date with Spain
Jan 04, 2018
Guidance on U.S. Transition Tax on Foreign Earnings
Jan 02, 2018
U.S. Publishes CbC Exchange Joint Statement with France and Exchange Arrangement with Spain
Jan 02, 2018
U.S. Tax Cuts and Jobs Act Signed into Law
Dec 26, 2017
U.S. Tax Cuts and Jobs Act Approved by Congress
Dec 21, 2017
U.S. Signs CbC Exchange Arrangement with Spain, Provides Operative Date for Arrangements with Guernsey and Malta
Dec 21, 2017
EU General Court Rejects U.S. Application for Leave to Intervene in Apple State Aid Case
Dec 20, 2017
IRS Releases Practice Units on Calculation of the IRC 956 Inclusion and Initial Stock Basis in S Corporations
Dec 19, 2017
Conference Report Published on Reconciled U.S. Tax Cuts And Jobs Act
Dec 18, 2017
Luxembourg Appeals Amazon State Aid Decision
Dec 18, 2017
Jersey Publishes CbC Exchange Arrangement with the U.S.
Dec 18, 2017
CbC Exchange Arrangement between Spain and the U.S. to be Signed
Dec 15, 2017
Agreement in Principle Reached on U.S. Tax Reform
Dec 14, 2017
U.S. to Spontaneously Exchange CbC Reports with France for 2016
Dec 14, 2017
EU Finance Ministers Voice Concerns on U.S. Tax Reform in Letter to Treasury Secretary
Dec 13, 2017
U.S. Joint Committee on Taxation Issues Comparison Report on House and Senate Tax Reform Bills
Dec 12, 2017
IRS Releases Practice Units on Employment Taxes and Tax Credits for U.S. Persons Abroad
Dec 11, 2017
U.S. IRS Publishes Competent Authority Arrangement with South Korea Clarifying Fiscal Domicile
Dec 11, 2017
U.S. Interest Rates on Overpaid and Underpaid Tax for Q1 2018
Dec 08, 2017
U.S. Signs CbC Exchange Arrangements with Bermuda and Jersey
Dec 08, 2017
U.S. Senate Passes Tax Reform Bill
Dec 04, 2017
U.S. Senate Tax Reform Bill Passes Budget Committee
Nov 29, 2017
U.S. Senate Finance Committee Publishes Text of Tax Reform Bill
Nov 27, 2017
IRS Releases Practice Units on Common Ownership and Control for Inbound and Outbound Transactions
Nov 27, 2017
U.S. IRS Advisory Council Releases Release Annual Report for 2017
Nov 21, 2017
U.S. House of Representative Passes Tax Reform Bill
Nov 17, 2017
Senate Committee Releases Modifications to Tax Reform Bill
Nov 16, 2017
U.S. Publishes CbC Exchange Arrangement with Portugal
Nov 15, 2017
IRS Releases Practice Units on Advance Pricing Agreements for Tangible Goods Transactions
Nov 14, 2017
U.S. Social Security Fact Sheet for 2018 Published
Nov 13, 2017
TIEA between Argentina and the U.S. has Entered into Force
Nov 13, 2017
SSA between Serbia the U.S. under Negotiation
Nov 13, 2017
U.S. House Tax Reform Bill Passes Committee and Senate Version Announced
Nov 10, 2017
Summary of U.S. Tax Reform Markup Amendments
Nov 09, 2017
U.S. Publishes CbC Exchange Arrangement with Mexico
Nov 08, 2017
U.S. Tax Reform: Impact on Companies with International Operations
Nov 06, 2017
U.S. Signs CbC Exchange Arrangement with Portugal
Nov 06, 2017
Update - U.S. IRS Clarification on Status of CbC Exchange Arrangements
Nov 06, 2017
U.S. Publishes CbC Exchange Arrangements with the Czech Republic, Finland, and Luxembourg
Nov 02, 2017
India Supreme Court Holds Contract Service Provider Does Not Constitute PE under India-U.S. Tax Treaty
Nov 02, 2017
Corrections Made to U.S. Regulations on Dividend Equivalents from Sources within the United States
Nov 01, 2017
U.S. IRS Updates CbC Exchange Arrangement Table to Provide Operative Date
Oct 31, 2017
U.S. Unlikely to Finalize all Needed CbC Exchange Arrangements by End of 2017
Oct 30, 2017
Singapore and U.S. to Sign TIEA by Year-End
Oct 27, 2017
U.S. 2017-2018 Priority Guidance Plan Issued
Oct 26, 2017
U.S. Signs CbC Exchange Arrangement with Mexico
Oct 26, 2017
U.S. Signs CbC Exchange Arrangement with Luxembourg
Oct 25, 2017
U.S. IRS Issues Inflation Adjustments for 2018
Oct 23, 2017
U.S. Publishes CbC Exchange Arrangements with Sweden
Oct 23, 2017
IRS Releases Practice Units on U.S. Real Property Holding Corporations, Entity Classification Regulations, and Accounting for Land Developers and Subcontractors
Oct 20, 2017
U.S. Publishes CbC Exchange Arrangements with Canada and Italy
Oct 20, 2017
IRS Releases Practice Unit on Failure to File Information Return with Respect to Certain Foreign Corporations
Oct 13, 2017
U.S. Treasury Publishes Report on Eight Regulations for Possible Withdrawal, Revocation, or Modification
Oct 11, 2017
U.S. Publishes CbC Exchange Arrangement with Greece
Oct 11, 2017
Uruguay Approves SSA with the U.S.
Oct 10, 2017
U.S. Signs CbC Exchange Arrangements with the Czech Republic, Finland, and Sweden
Oct 06, 2017
European Commission Finds Luxembourg Granted Illegal State Aid to Amazon
Oct 05, 2017
U.S. Provides One-Year Delay for Final and Temporary Regs on Foreign Currency Gains/Losses
Oct 05, 2017
Greece and the U.S. Sign CbC Exchange Arrangement
Oct 05, 2017
Italy and the U.S. Sign CbC Exchange Arrangement
Oct 05, 2017
South Dakota Petitions U.S. Supreme Court on Economic Nexus Law
Oct 04, 2017
U.S. Joint Committee on Taxation Publishes Report on International Tax Reform for Public Hearing
Oct 03, 2017
U.S. District Court Holds Inversion Rule Unlawfully Issued
Oct 02, 2017
U.S. IRS Consults on New APA Template
Sep 29, 2017
US Tax Reform Framework Published
Sep 28, 2017
OECD Releases First Batch of MAP Peer Review Results
Sep 27, 2017
Big Six U.S. Tax Reform Plan Expected Soon
Sep 26, 2017
U.S. Negotiating CbC Exchange Arrangement with Greece
Sep 25, 2017
U.S. Publishes CbC Exchange Arrangement with the United Kingdom
Sep 25, 2017
U.S. Legislation Proposed to Provide De Minimis Gains Exclusion for Virtual Currency
Sep 22, 2017
U.S. Signs CbC Exchange Arrangement with Colombia
Sep 22, 2017
IRS Publishes Model Competent Authority Arrangement for Exchange of CbC Reports based on Mutual Assistance Convention
Sep 21, 2017
IRS Releases Practice Units on Sourcing of Income, Creditable Foreign Taxes, Inbound High Value Services, and other Issues
Sep 19, 2017
U.S. Signs CbC Exchange Arrangement with Lithuania
Sep 14, 2017
U.S. Interest Rates on Overpaid and Underpaid Tax for Q4 2017
Sep 13, 2017
Corrections Made to U.S. Regulations on Guidance for Determining Stock Ownership
Sep 08, 2017
WTO Appellate Body Reverses Panel Finding on Boeing Tax Breaks
Sep 07, 2017
U.S. Negotiating CbC Exchange Arrangement with Bermuda
Sep 07, 2017
U.S. IRS Updates CbC Exchange Status Table to Include Negotiations Status
Aug 31, 2017
U.S. Publishes CbC Exchange Arrangement with Australia
Aug 25, 2017
U.S. Signs CbC Exchange Arrangement with the United Kingdom
Aug 24, 2017
U.S. Publishes CbC Exchange Arrangement with Jamaica
Aug 23, 2017
First Round of NAFTA Revision Negotiations Held
Aug 18, 2017
U.S. Court Upholds IRS Application of Principal Purpose Test for Discretionary Treaty Benefits
Aug 17, 2017
U.S. Publishes CbC Exchange Arrangement with Malta
Aug 15, 2017
Slovenia Ratifies Pending SSA with the U.S.
Aug 15, 2017
IRS Now Accepting Country-by-Country Reports
Aug 14, 2017
U.S. Senators Call on Treasury to Maintain Section 385 Debt-Equity Regulations
Aug 11, 2017
Legislation Introduced in the U.S. House of Representative Targeting Tax Havens and Jobs Outsourcing
Aug 10, 2017
U.S. Publishes CbC Exchange Arrangements with Estonia and Isle of Man
Aug 10, 2017
U.S. Provides Delay for Certain Dividend Equivalent Rules
Aug 09, 2017
U.S. Treasury List of International Boycott Countries Published
Aug 07, 2017
U.S. Signs CbC Exchange Arrangements with Australia and Estonia
Aug 04, 2017
U.S. Publishes CbC Exchange Arrangement with Brazil
Aug 04, 2017
U.S. to Delay Documentation Requirements under Earnings Stripping Rules
Aug 03, 2017
U.S. Publishes CbC Exchange Arrangement with Belgium
Aug 03, 2017
IMF Releases Report on U.S. Economic Developments and Policies Including Tax Reform Recommendations
Aug 01, 2017
Joint Statement Published on Commitment to U.S. Tax Reform
Jul 31, 2017
U.S. Publishes CbC Exchange Arrangements with Denmark and Guernsey
Jul 31, 2017
U.S. Stop Corporate Inversions Act Reintroduced
Jul 28, 2017
Israel and U.S. Considering Protocol to Revise Current Tax Treaty
Jul 27, 2017
U.S. Final and Temporary Regulations Published on Return Due Date and Extended Due Date Changes
Jul 26, 2017
Croatia Looking to Conclude Tax Treaty with the U.S.
Jul 25, 2017
U.S. Signs CbC Exchange Arrangements with Belgium, Brazil, Isle of Man, Jamaica, and Malta
Jul 24, 2017
U.S. Publishes CbC Exchange Arrangements with Ireland, Latvia, and the Slovak Republic
Jul 24, 2017
Ukraine State Fiscal Service Clarifies when a Distributor's Payments to a Software Copyright Holder are Subject to Royalty Withholding Tax under U.S. Tax Treaty
Jul 20, 2017
G20 Leaders' Declaration Published following Hamburg Summit
Jul 10, 2017
US Publishes CbC Exchange Arrangement with South Korea
Jul 06, 2017
U.S. IRS Releases Final Form 8975 - Country-by-Country Report
Jul 03, 2017
Google Fined EUR 2.42 billion by European Commission for Breach of EU Antitrust Rules
Jun 29, 2017
U.S. IRS Publishes CbC Report FAQ
Jun 28, 2017
U.S. House Speaker Ryan Confident in Passing Tax Reform in 2017
Jun 26, 2017
U.S. Signs CbC Exchange Arrangements with Denmark, Guernsey, Ireland, Latvia, and the Slovak Republic, and South Korea
Jun 23, 2017
U.S. IRS Issues Interest Rates on Overpaid and Underpaid Tax for Q3 2017
Jun 14, 2017
CbC Exchange Arrangement between Canada and U.S. Signed
Jun 12, 2017
Treasury Official on Why U.S. Did Not Sign BEPS Multilateral Instrument
Jun 12, 2017
IRS Releases Practice Unit on Functional Currency Determination
Jun 08, 2017
U.S. Competent Authority Agreement on the Exchange of CbC Reports with South Africa Signed
Jun 06, 2017
U.S. Competent Authority Agreements on the Exchange of CbC Reports with Iceland and New Zealand
Jun 02, 2017
CbC Exchange Agreement between Norway and U.S. Signed
May 24, 2017
CbC Exchange Agreement between Netherlands and U.S.
May 18, 2017
South Africa Negotiating CbC Exchange Agreements with Panama, Singapore, and the U.S.
May 18, 2017
G7 Finance Ministers Communiqué and Declaration on Fighting Tax Crimes Published
May 17, 2017
Trump Interview on U.S. Tax Plans
May 15, 2017
U.S. Signs Two Competent Authority Agreements for Exchange of CbC Reports
May 02, 2017
U.S. IRS Appeals Court Decision that Overturned Medtronic 482 Adjustments
May 01, 2017
Principles of Trump U.S. Tax Reform Plan
Apr 27, 2017
U.S. Consultation on Recommendations for 2017-2018 Priority Guidance Plan
Apr 26, 2017
IRS Releases Practice Unit on Physical Presence Test for Foreign Earned Income Exclusion
Apr 26, 2017
IRS Releases Practice Unit on Expense Allocation/Apportionment in Calculation FTC Limitation
Apr 24, 2017
IRS Publishes Model Competent Authority Agreements for Exchange of CbC Reports
Apr 21, 2017
IRS Releases Practice Unit on FTC General Principles
Apr 14, 2017
U.S. Treasury List of International Boycott Countries Published
Apr 07, 2017
U.S. Publishes Annual APA report for 2016
Mar 31, 2017
EU Parliament Members Push for Improved Transparency During Recent U.S. Visit
Mar 28, 2017
U.S. Infrastructure Legislation Submitted in Congress including Measures for Profit Repatriation and Deadline for Broader Tax Reforms
Mar 24, 2017
U.S. Bill to Extend Puerto Rico Domestic Production Activities Deduction Permanently
Mar 23, 2017
G20 Finance Ministers Communiqué Published
Mar 22, 2017
U.S. 2018 Budget Blueprint Published
Mar 17, 2017
Puerto Rico's Oversight Board Approves Revised Fiscal Plan
Mar 16, 2017
U.S. IRS Issues Interest Rates on Overpaid and Underpaid Tax for Q2 2017
Mar 14, 2017
Corporate Tax Dodging Prevention Act Introduced in U.S. Senate
Mar 13, 2017
U.S. IRS Expects CbC Report Exchange Agreements to be Completed in Timely Manner but May Not Cover all Countries
Mar 13, 2017
U.S. Congressional Budget Office Report: International Comparisons of Corporate Income Tax Rates
Mar 10, 2017
IRS Releases Practice Unit on Foreign and Domestic Loss Impacts on the Foreign Tax Credit
Mar 03, 2017
Vietnam Ratifies Tax Treaty with the U.S.
Mar 02, 2017
U.S. Supreme Court Upholds (Indirectly) Florida Court Position on Sales Tax on Out-of-State Sales
Mar 01, 2017
U.S. IRS Publishes Draft Instructions for Form 8975
Feb 27, 2017
Action brought Against EU Commission by Apple Regarding Ireland Decision Published
Feb 24, 2017
Norway Negotiating Tax Instruments with 11 Countries
Feb 23, 2017
U.S. IRS Publishes "Dirty Dozen" List of Tax Scams for 2017
Feb 21, 2017
IRS Releases Practice Units on Hedge Funds and Penalties for Failing to Timely File Return on Interests in Foreign Partnerships
Feb 16, 2017
Japan Clarifies Treatment of U.S. Limited Partnerships as Fiscally Transparent
Feb 13, 2017
U.S. House Democrats Oppose Resolution to Repeal Debt-Equity Regs
Feb 10, 2017
Swiss Tax Treaties with Anti-Abuse Provisions
Feb 08, 2017
U.S. End Outsourcing Act would Deny Federal Contracts and Incentives for Companies Outsourcing Jobs
Feb 07, 2017
Joint Resolution Introduced in U.S. Congress Disapproving Treasury Debt-Equity Regs
Feb 06, 2017
IRS Releases Practice Unit on Basket Transactions
Feb 06, 2017
IRS Announces Initial Rollout of Large Business and International Compliance Campaigns
Feb 02, 2017
IRS Releases Practice Units on Exchange Gains/Losses, Exchange Rates, Penalties, and Other Issues
Feb 01, 2017
U.S. GAO Publishes Report on the Potential Impact on IRS and U.S. Multinationals of Revised International Guidance on Transfer Pricing
Jan 31, 2017
Corrections Made to U.S. Debt-Equity Regulations
Jan 27, 2017
U.S. Publishes Final and Temporary Regulations: Dividend Equivalents From Sources Within the United States
Jan 25, 2017
U.S. Treasury Working Paper on the Effect of a Cash Flow Tax
Jan 24, 2017
Brazil Clarifies Withholding Tax Obligation for Payments for Technical Services to Canada and the U.S.
Jan 24, 2017
U.S. IRS Publishes 2016 Tax Changes for Individual Taxpayers
Jan 23, 2017
U.S. IRS Releases Revenue Procedure on CbC Voluntary Filing
Jan 20, 2017
SSA between Slovenia and the U.S. Signed
Jan 20, 2017
U.S. IRS Publishes Final and Temporary Regulations: Guidance for Determining Stock Ownership; Rules Regarding Inversions and Related Transactions
Jan 19, 2017
Social Security Agreement between the U.S. and Uruguay Signed
Jan 12, 2017
U.S. IRS Publishes Practice Unit on Arm's Length Determination for Transfers of Intangibles Property and CSAs
Jan 06, 2017
U.S. IRS Updates Guidance on Available Advice for Taxpayers
Jan 04, 2017
U.S. Releases Final and Temporary FATCA Regulations
Jan 03, 2017
TIEA between Argentina and the U.S. Signed
Dec 27, 2016
U.S. Final Regulations Published Concerning Treatment of Certain Transfers of Property to Foreign Corporations
Dec 20, 2016
U.S. to Exchange Unilateral APAs as per BEPS Action 5 by the End of the Year
Dec 19, 2016
U.S. Final Reporting Regs for Foreign-Owned Domestic Disregarded Entities to Improve Transparency
Dec 14, 2016
U.S. IRS Issues Interest Rates on Overpaid and Underpaid Tax for Q1 2017
Dec 14, 2016
SSA between Brazil and the U.S. Transmitted to U.S. Congress
Dec 14, 2016
U.S. Senator Proposes Progressive Consumption Tax Act
Dec 13, 2016
Dutch Tax Treaty Negotiation Plans
Dec 13, 2016
U.S. IRS Publishes Draft CbC Reporting Forms
Dec 12, 2016
U.S. Final and Temporary Regs on Foreign Currency Gains/Losses Published
Dec 09, 2016
U.S. Treasury List of International Boycott Countries Published
Dec 05, 2016
U.S. GAO Finds New Debt-Equity Regs in Compliance with Promulgation Rules
Dec 01, 2016
WTO Rules Boeing Tax Breaks Illegal
Nov 30, 2016
U.S. IRS Publishes Practice Units on Portfolio Debt Exemption, Employee Share of Employment Taxes, and Self-Employment Taxes
Nov 16, 2016
U.S. Treasury Inspector General for Tax Administration Releases Report on Virtual Currencies Tax Compliance
Nov 11, 2016
Congressional Research Service Issues Report on U.S. Corporate Tax Integration
Nov 04, 2016
U.S. IRS Releases 2016-2017 Priority Guidance Plan First Quarter Update
Nov 03, 2016
U.S. IRS Announces Inflation Adjustments for 2017
Oct 31, 2016
Romania to Sign SSA with the U.S.
Oct 31, 2016
U.S. Social Security Fact Sheet for 2017 Published
Oct 27, 2016
U.S. IRS Publishes Practice Units on Identifying Foreign Goodwill or Going Concern and Source of Income for Nonresident Alien Individuals
Oct 19, 2016
IRS Announces Position on Mexican Unilateral APAs Involving Maquiladora Operations
Oct 18, 2016
Update - U.S. Chamber of Commerce Lawsuit Challenging Rule Allowing IRS to Disregard Recent Acquisitions in Determining Inversion Thresholds
Oct 17, 2016
U.S. IRS Publishes Revised Publication 901 on Income Tax Reductions / Exemptions under Tax Treaties
Oct 17, 2016
U.S. Treasury Issues Final Debt-Equity Regulations
Oct 14, 2016
U.S. Senator Hatch Seeks Clarification from Treasury on Use of Secret Memo Regarding Section 385 Debt-Equity Regulations
Oct 13, 2016
Tax Treaty between Colombia and the U.S. under Negotiation
Oct 04, 2016
U.S. Legislation Would Introduce New Tax on Imports from Countries that Provide Indirect Tax Rebates
Sep 28, 2016
Tax Treaty between Argentina and the U.S. under Negotiation
Sep 28, 2016
U.S. IRS Publishes Practice Units on FTC Limitation for Compensation Arrangements and Comparison of the Arm’s Length Standard with Other Valuation Approaches
Sep 27, 2016
U.S. Rep. Pocan Introduces Bill to Strengthen Corporate Tax Disclosure and Transparency including Disclosure of CbC Information
Sep 26, 2016
Amazon and McDonald's to be Next for EU State Aid Investigations
Sep 22, 2016
U.S. IRS Issues Interest Rates on Overpaid and Underpaid Tax for Q4 2016
Sep 21, 2016
Correcting Amendment to U.S. CbC Regulations Published
Sep 20, 2016
U.S. to Limit Foreign Tax Credit Availability in Relation to Foreign Adjustments
Sep 19, 2016
German Court Finds U.S. Dating Site Subject to VAT
Sep 16, 2016
U.S. Treasury Secretary Lew Says EU State Aid Investigations Highlight Need for U.S. Tax Reform
Sep 15, 2016
U.S. Bill Introduced to Repeal FATCA Reporting Obligation
Sep 12, 2016
SSA between Hungary and the U.S. has Entered into Force
Sep 09, 2016
G20 Leaders Summit Communiqué and OECD Report Published
Sep 07, 2016
Silicon Valley Tax Directors Group Urges Dutch Government to Maintain Current Tax Regime
Sep 01, 2016
U.S. Treasury White Paper on European Commission’s State Aid Investigations
Aug 30, 2016
Ireland Consults on Updating Tax Treaty with the U.S.
Aug 30, 2016
U.S. IRS Publishes Practice Units on Disposition of a U.S. Real Property Interest and the Foreign Earned Income Exclusion and Foreign Housing Deduction for Individuals
Aug 26, 2016
U.S. Treasury Seeks Public Comment on Burden Estimate for CbC Reporting Form 8975
Aug 25, 2016
U.S. House and Senate Republicans Continue to Urge Revisions to Proposed Debt-Equity Regulations
Aug 24, 2016
U.S. IRS Releases 2015-2016 Priority Guidance Plan Fourth Quarter Update and the Initial 2016-2017 Plan
Aug 22, 2016
Indian Tax Tribunal Holds that No Tax is Due on Payments for Taxation and Audit Services Provided Overseas
Aug 10, 2016
U.S. Treasury List of International Boycott Countries Published
Aug 09, 2016
U.S. Chamber of Commerce Files Lawsuit Challenging Rule Allowing IRS to Disregard Recent Acquisitions in Determining Inversion Thresholds
Aug 08, 2016
Singapore and the U.S. to Negotiate TIEA and Reciprocal FATCA Agreement
Aug 04, 2016
Facebook Facing Tax Liability of up to USD 5 Billion due to Intangibles Transfer Pricing Issues
Aug 02, 2016
U.S. to No Longer Treat FATCA Agreements as in Effect if Not in Force
Aug 01, 2016
G20 Finance Ministers Issue Communiqué following Chengdu Meeting
Jul 27, 2016
U.S. IRS Publishes Practice Units on Qualified Business Units, Nonfunctional Currency Transactions and Exchange Gain/Loss on Currency Transactions
Jul 22, 2016
Indian Tribunal Holds Fees for Overseas Marketing Services do Not Constitute FTS under Singapore and UK Tax Treaties
Jul 21, 2016
U.S. Congressman Issues Alternate Tax Reform Plan
Jul 20, 2016
New U.S. Disclosure Rules for Resource Extraction Issuers May be Fulfilled with Similar Reports Filed in Canada or the EU
Jul 19, 2016
U.S. IRS Publishes Practice Units on FDAP Payments – Source of Income
Jul 18, 2016
U.S. IRS Publishes Practice Units on Corporate Inversions and Failure to File Return of Transfer of Property to Foreign Corporation
Jul 08, 2016
U.S. Senators Urge Treasury to Delay Proposed Debt-Equity regulations under IRC section 385
Jul 07, 2016
82 Countries Committed to Implementation of Four Minimum Standards of OECD BEPS Project under Inclusive Framework
Jul 05, 2016
U.S. CbC Regulations Published in Federal Register
Jul 01, 2016
U.S. Final CbC Regulations Released
Jun 30, 2016
House GOP Unveils Ambitious Tax Reform Plan
Jun 27, 2016
US, Luxembourg agree to tax treaty changes to prevent double nontaxation
Jun 27, 2016
U.S. Multistate Tax Commission Presents Draft Information Exchange Agreement
Jun 23, 2016
U.S. Senators Request Exchange of Information Amendments in Pending Treaties/Protocols
Jun 23, 2016
U.S. Tax Court Finds IRS Income Allocation Unreasonable
Jun 14, 2016
European Commission Publishes Public Version of Letter to Luxembourg on Formal Investigation into Illegal State Aid Provided to McDonald's
Jun 09, 2016
U.S. IRS Issues Interest Rates on Overpaid and Underpaid Tax for Q3 2016
Jun 09, 2016
U.S. IRS Commissioner Urges Congress to Enact Legislation for the Implementation of CRS
Jun 09, 2016
U.S. IRS Publishes Practice Units on Determination of Source of Income for FDAP Purposes and Related Withholding
Jun 07, 2016
U.S. Treasury Finalizing Details of CbC Reporting Regs
Jun 06, 2016
Costa Rica Negotiating TIEAs with Bermuda, Panama, South Korea and the U.A.E. and Protocol to TIEA with the U.S.
Jun 03, 2016
G7 Declaration Following Japan Summit Encourages Adoption of BEPS Measures and Measures to Improve Transparency
Jun 01, 2016
Protocol to the SSA between the Czech Republic and the U.S. has Entered into Force
May 31, 2016
U.S. Joint Committee on Taxation Publishes Overview of the Tax Treatment of Corporate Debt and Equity
May 27, 2016
SSA between Albania and the U.S. under Negotiation
May 24, 2016
U.S. Bill Introduced to Target Hopscotch Lending and Decontrolling
May 19, 2016
OECD Forum on Tax Administration Agrees on Common Transmission System for CbC and CRS Information
May 18, 2016
US IRS Issues Practice Unit on Taxpayer’s Affirmative Use of IRC 482 for Transfer Pricing Purposes
May 16, 2016
EU Greens/EFA Publish Report on the Role of the U.S. as a Tax Haven
May 13, 2016
U.S. Issues Modified Pre-Filing Agreement Program Revenue Procedure
May 12, 2016
U.S. Won't Adopt BEPS Project PE Standard into Tax Treaties until Profit Attribution Sorted out
May 10, 2016
U.S. Treasury Announces New Rules and Legislation to Increase Transparency
May 09, 2016
Exit Tax Bill Introduced in U.S. House of Representatives
May 06, 2016
New South Dakota Economic Nexus Law Meant to be Challenged
May 04, 2016
U.S. Legislation Introduced to Ensure that Corporate Tax Rate Cuts would Apply for Pass-through Entities
May 03, 2016
U.S. Treasury Considering Voluntary CbC Report Filing for 2016
May 02, 2016
U.S. Court Dismisses Challenge of the Constitutionality of FATCA
Apr 29, 2016
U.S. Senate Finance Committee Hearing: Business Tax Reform Issues
Apr 28, 2016
U.S. Senator to Propose Tax Reform with More Carrots and Fewer Sticks
Apr 25, 2016
Former U.S. Treasury Officials Urge Secretary Lew to Reconsider Latest Anti-Inversion Regs and Instead Focus on Tax Reform
Apr 20, 2016
U.S. IRS Notice for a Public Hearing on CbC Reporting Regulations
Apr 19, 2016
Five EU Countries Announce Plans to Develop Multilateral System for Automatic Exchange of Beneficial Ownership Info and G20 Listens
Apr 18, 2016
U.S. Treasury Considering New Rules on Beneficial Ownership
Apr 12, 2016
U.S. Treasury Publishes List of International Boycott Countries
Apr 12, 2016
U.S. IRS Publishes Practice Units on Allocation of Income under IRC 482, Inbound Resale Price Method, and Computing Foreign Base Company Income
Apr 07, 2016
U.S. Issues New Regulations on Inversions and Earnings Stripping
Apr 06, 2016
Tax Haven Legislation Introduced in Minnesota Senate
Mar 31, 2016
Albania Looking to Negotiate Tax Treaty with the U.S.
Mar 23, 2016
U.S. Revises Interest Rates on Overpaid and Underpaid Tax for Q2 2016
Mar 22, 2016
U.S. IRS Publishes Practice Units on FDAP Income, Interest Expense Limitation Computation, Foreign Personal Holding Company Income, and Others
Mar 18, 2016
U.S. Interest Rates on Overpaid and Underpaid Tax Remain Unchanged for Q2 2016
Mar 15, 2016
U.S. Official Says No Exchange of CbC Reports with Countries that Make Information Public In Response to EU Plans
Mar 14, 2016
Colorado and Maine Targeting Tax Havens
Mar 14, 2016
U.S. Senator Reintroduces Pay What You Owe Before You Go Act Targeting Corporate Inversions
Mar 11, 2016
U.S. Treasury Responds to Senate Request to Consider Tougher Response to Perceived Targeting of U.S. Companies in EU State Aid Investigations
Mar 09, 2016
U.S. IRS Publishes Practice Units on Residual Profit Split Method - Outbound, Review of Transfer Pricing Documentation, and Outbound Services to CFCs
Mar 08, 2016
U.S. CbC Reporting Regulations to Apply from 1 July 2016
Mar 04, 2016
European Commissioner Responds to U.S. Treasury's Concerns that State Aid Investigations are Targeting U.S. Multinationals
Mar 04, 2016
Cuba removed from U.S. Foreign Tax Credit Blacklist
Mar 03, 2016
U.S. Tax Court Opinion that Determination of Separate Taxable Income not needed for Group Transfer Pricing Adjustment
Mar 02, 2016
U.S. Legislation Targeting Corporate Earnings Stripping Introduced
Feb 26, 2016
U.S Congressman Hopes for Passage of Legislation in 2016 Restricting the Exchange of CbC Reports
Feb 25, 2016
U.S. IRS Publishes "Dirty Dozen" List of Tax Scams for 2016
Feb 24, 2016
U.S. IRS Publishes Practice Units on Outbound Transfers of Foreign Stock, the Residual Profit Split Method, Gross Effectively Connected Income of a Foreign Corporation, and Others
Feb 22, 2016
U.S. Treasury Issues Revised Model Income Tax Convention
Feb 19, 2016
U.S. Treasury Secretary Addresses Concerns with EU State Aid Investigations in Letter to European Commission President
Feb 16, 2016
U.S. Administration's Budget Proposals for 2017
Feb 12, 2016
U.S. IRS Publishes Practice Units on Dividends or Interest from CFCs, Outbound Transfer of Stock, and Pricing of PCT in CSA Acquisition of Subsequent IP
Feb 11, 2016
Trans-Pacific Partnership Agreement Signed
Feb 11, 2016
U.S. IRS Issues Additional Inflation Adjustments for 2016 for the Election to Expense Certain Depreciable Assets and Others
Feb 10, 2016
U.S. IRS Publishes Practice Units on Intercompany Interest Rates, Cost Sharing Arrangements, and other Issues
Feb 05, 2016
House Ways and Means Committee to Draft U.S. International Tax Reform Bill
Feb 03, 2016
U.S. Ends Suspension of Bilateral APAs with India
Feb 03, 2016
U.S. Treasury Publishes List of International Boycott Countries
Feb 02, 2016
U.S Congressmen Promises Tax Reform to Support U.S. Businesses following Release of the EU Anti Avoidance Package
Feb 01, 2016
U.S. IRS Publishes Practice Units on Exchange of Information
Jan 22, 2016
U.S. Senate Finance Committee Requests that Treasury Caution the EU Commission on EU State Aid Investigations Impacting U.S. Companies
Jan 20, 2016
U.S. IRS Publishes Revised List of Areas in which Tax Rulings will not be Issued
Jan 06, 2016
Apple Agrees to Pay EUR 318 Million to Settle Italian Tax Dispute
Dec 31, 2015
U.S. Interest Rates on Overpaid and Underpaid Tax Remain Unchanged for Q1 2016
Dec 31, 2015
U.S. IRS Issues Proposed CbC Reporting Regulations
Dec 23, 2015
U.S. Tax Extenders Legislation Approved
Dec 23, 2015
U.S. CbC Reporting Regulations Expected Soon
Dec 21, 2015
New Tax Treaty between the U.S. and Luxembourg under Negotiation
Dec 21, 2015
Protocols to the TIEAs between the U.S. and the Isle of Man and Jersey have Entered into Force
Dec 18, 2015
Indian Tribunal Holds that Make Available Clause Concerning Fees for Technical Services may be Incorporated by MFN Clause of the India-Dutch Tax Treaty
Dec 16, 2015
U.S. IRS Updates FATCA General FAQs on Compliance Issues
Dec 15, 2015
U.S. Tax Extenders Bill Sent to House Rules Committee
Dec 10, 2015
Update - EU Commission Opens Formal Investigation into Luxembourg's Tax Treatment of McDonald's
Dec 07, 2015
U.S. IRS Publishes Practice Units on Foreign Trusts and Structures used to Conceal Beneficial Ownership of Foreign Accounts and Assets
Dec 07, 2015
U.S. IRS Publishes Six International Practice Units
Nov 25, 2015
U.S. Treasury Announces Additional Actions to Counter Corporate Inversions
Nov 24, 2015
U.S. Treasury to Issue Additional Guidance to Deter Corporate Inversions and Calls on Congress for Legislative Action
Nov 20, 2015
Tax Treaty between Armenia and the U.S. to be Negotiated
Nov 18, 2015
UK Announces Tax Treaty and Protocol Negotiation Plans
Nov 18, 2015
U.S. Treasury Responds to Senate Finance Committee and House Ways and Means Committee Letter on CbC Regs
Nov 16, 2015
U.S. Senate Foreign Relations Committee Approves Pending Tax Treaties and Protocols
Nov 16, 2015
OECD Holds Inaugural Meeting for the BEPS Multilateral Instrument
Nov 12, 2015
U.S. Lawmakers Introduce Legislation Intended to Prevent Inversions by Limiting Interest Expense Deductions and Terminating CFC Active Income Deferral
Nov 12, 2015
U.S. IRS Publishes International Practice Units on Licensed IP to a Foreign Subsidiary and Deemed Annual Royalty Income
Nov 09, 2015
Washington DC Council Removes Tax Haven Black List
Nov 05, 2015
U.S. IRS Issues 2015-2016 Priority Guidance Plan First Quarter Update
Nov 03, 2015
U.S. IRS Publishes Ten International Practice Units
Nov 02, 2015
U.S. Treasury Official Urges Senate to Pass Pending Tax Treaties and Protocols
Nov 02, 2015
U.S. IRS Announces Inflation Adjustments for 2016
Oct 30, 2015
U.S Legislative Proposal to Address Puerto Rico’s Urgent Fiscal Situation
Oct 29, 2015
U.S. Social Security Fact Sheet for 2016 Published
Oct 23, 2015
Protocol to the TIEA between Guernsey and the U.S. has Entered into Force
Oct 19, 2015
Tax Treaty between Liechtenstein and U.S. under Negotiation
Oct 13, 2015
U.S. to Issue CbC Reporting Regulations by the End of the Year
Oct 09, 2015
U.S. IRS Announces Start of Automatic Exchange of Information under FATCA IGAs
Oct 07, 2015
OECD Publishes Final BEPS Package
Oct 06, 2015
U.S. Court Holds Denial of Discretionary Tax Treaty Benefits subject to Judicial Review
Oct 01, 2015
U.S. Issues Regulations on Dividend Equivalents from Sources within the U.S.
Sep 25, 2015
Five Permanent Extenders Bills Passed by U.S. House Ways and Means Committee
Sep 21, 2015
U.S. Issues Regulations Clarifying Coordination of Transfer Pricing Rules with Other Code Provisions
Sep 18, 2015
U.S. IRS Publishes International Practice Units on Liquidation of a Foreign Corporation and Accounting for Intangibles and Services Associated with Tangible Property
Sep 15, 2015
U.S. Court Affirms that Economic Substance Doctrine Applies to the Foreign Tax Credit Regime
Sep 11, 2015
U.S. Publishes Regulations on CFCs, Foreign Partnerships and Active the Rents and Royalties Exception
Sep 10, 2015
U.S. Interest Rates on Overpaid and Underpaid Tax Remain Unchanged for Q4 2015
Sep 09, 2015
Chilean Senate Approves Tax Treaty with the U.S.
Sep 08, 2015
U.S. IRS Publishes International Practice Units on Outbound Sales Transfer Pricing Issues and Foreign-to-Foreign Transactions Income Inclusion
Sep 04, 2015
U.S. IRS Updates General and ICMM FATCA FAQs
Sep 03, 2015
Washington DC Adopts Tax Haven Blacklist
Sep 02, 2015
U.S. Congressmen Reiterate Concerns with Treasury's Plans to Implement CbC Reporting
Aug 31, 2015
U.S. IRS Publishes Ten International Practice Units
Aug 25, 2015
U.S. IRS Publishes Procedures for Competent Authority Assistance and APAs
Aug 14, 2015
U.S. IRS Publishes Five International Practice Units
Aug 11, 2015
U.S. IRS Updates General FATCA FAQ
Aug 07, 2015
Changes to U.S. Tax Return Deadlines Included in Highway Funding Bill
Aug 06, 2015
U.S. Bill Introduced to Permanently Extend Dividends Received Deduction
Aug 04, 2015
U.S. Congress Passes Three-Month Highway Funding Bill without Tax Reform
Aug 04, 2015
U.S. IRS Publishes Initial Version of the 2015-2016 Priority Guidance Plan
Aug 03, 2015
U.S. Senators Announce Support for House Proposal for an Innovation Box Regime
Jul 31, 2015
U.S. Tax Court Rules on the Validity of the Requirement that Stock-Based Compensation Costs be Included under Cost-Sharing Agreements
Jul 31, 2015
U.S. Congressmen Release Draft Innovation Box Legislation
Jul 30, 2015
U.S. Senator Says OECD BEPS Action Items Require Congressional Approval in order to be Implemented
Jul 20, 2015
U.S. Bill introduced in the House of Representatives that would Modify Rules Relating to Inverted Corporations
Jul 17, 2015
IRS Makes Numerous Updates to FATCA Systems FAQ
Jul 16, 2015
U.S. Treasury Publishes List of International Boycott Countries
Jul 14, 2015
U.S. Senate International Tax Reform Working Group Issues Final Report including Bipartisan Framework for Reform
Jul 10, 2015
Tax Treaty between the U.S. and Vietnam Signed
Jul 10, 2015
U.S. Senator Proposes Amendment to Fund early Childhood Education by Amending Inversion Rules
Jul 09, 2015
U.S. IRS Publishes Updated Publication on Withholding of Tax on Nonresident Aliens and Foreign Entities
Jul 08, 2015
SSA between Brazil and the U.S. Signed
Jul 03, 2015
Tax Treaty and SSA between San Marino and the U.S. to be Negotiated
Jul 02, 2015
Bill Introduced in the U.S. Senate to Restrict the Insurance Business Exception to the PFIC Rules
Jun 30, 2015
U.S. House Subcommittee Hearing Held on Repatriation of Foreign Earnings as a Source of Funding for the Highway Trust Fund
Jun 26, 2015
U.S. Treasury Official Says no New Regulations Needed to Implement Transfer Pricing Guidelines under BEPS Actions 8, 9 and 10
Jun 26, 2015
U.S. Congress to Spend Rest of the Year on International Tax Reform while Holding off on Comprehensive Reform
Jun 18, 2015
U.S. IRS Updates General FATCA FAQ
Jun 16, 2015
U.S. Treasury Considering Earlier CbC Reporting Deadline
Jun 15, 2015
U.S. Congressmen Call for Greater Engagement with Treasury in Regard to the OECD BEPS Project
Jun 12, 2015
U.S. Senate Tax Reform Working Groups Developing Tax Reform Proposals Including IP and Corporate Integration Regimes
Jun 11, 2015
U.S. Interest Rates on Overpaid and Underpaid Tax Remain Unchanged for Q3 2015
Jun 10, 2015
U.S. Substantial Business Activities Regulations for an Expanded Affiliated Group Issued
Jun 08, 2015
SSA between the U.S. and Uruguay Initialed
Jun 04, 2015
Income from Booking Seats/Space under Code Sharing Agreements with Third Party Airlines not Exempt under India-U.S. Income Tax Treaty
May 28, 2015
US Treasury Issues Proposed Revisions to the US Model Tax Convention
May 21, 2015
U.S. IRS Issues Notice for Comments on New Withholding Tax Refund Regulations
May 06, 2015
US IRS Issues 2014-2015 Priority Guidance Plan Third Quarter Update
May 04, 2015
Hungary Ratifies SSA with the U.S.
Apr 30, 2015
U.S. Legislators Re-Introduce Legislation Banning Federal Contracts for Inverted Companies
Apr 20, 2015
Invest in Transportation Act of 2015 Introduced in the U.S. Senate
Apr 17, 2015
U.S. IRS Publishes Notice Inviting Comment for 2015-2016 Guidance Plan
Mar 19, 2015
U.S. Interest Rates on Overpaid and Underpaid Tax Remain Unchanged for Q2 2015
Mar 18, 2015
Liechtenstein Expresses Interest in Negotiating a Tax Treaty with the U.S.
Mar 16, 2015
U.S. Senators Reintroduce Internet Sales Tax Bill
Mar 12, 2015
U.S. Economic Growth and Family Fairness Tax Reform Plan
Mar 11, 2015
U.S. Senator Sends Letter to President Obama Requesting Executive Action on 6 Tax "Loopholes"
Mar 05, 2015
U.S. Planning to Meet Proposed OECD Deadline for BEPS Country-by-Country Reporting
Feb 27, 2015
SSA between Latvia and the United States under Negotiation
Feb 17, 2015
Tax Treaty between Croatia and the United States under Negotiation
Feb 17, 2015
U.S. IRS Completes the "Dirty Dozen" Tax Scams for 2015
Feb 13, 2015
Proposed Invest in Transportation Act of 2015 Includes Reduced U.S. Tax Rate for Repatriated Foreign Earnings
Feb 11, 2015
Protocol to the TIEA between Liechtenstein and the U.S. has Entered into Force
Feb 10, 2015
Foreign Earnings Reinvestment Act Introduced in U.S. Congress
Feb 06, 2015
SSA between Hungary and the U.S. Signed
Feb 04, 2015
U.S. Fiscal 2016 Budget Sent to Congress
Feb 02, 2015
Negotiations to Resume for SSA between Indian and the U.S.
Jan 27, 2015
U.S. Senate Finance Committee Tax Reform Working Groups
Jan 26, 2015
U.S. Stop Corporate Inversions Act Reintroduced in House and Senate
Jan 21, 2015
Stop Tax Haven Abuse Act Reintroduced in U.S. Congress
Jan 14, 2015
Indian Tribunal Rules on Taxation of Payments for U.S. Employees Seconded to India
Dec 31, 2014
Tax Increase Prevention Act of 2014 Passed by U.S. Senate
Dec 19, 2014
U.S. Consumption Tax Proposal Introduced in the Senate
Dec 18, 2014
U.S. IRS Updates General FATCA FAQ
Dec 16, 2014
U.S. Interest Rates on Overpaid and Underpaid Tax Remain Unchanged for Q1 2015
Dec 10, 2014
U.S. Treasury Publishes List of International Boycott Countries
Dec 10, 2014
Tax Increase Prevention Act of 2014 Passed by U.S. House of Representatives
Dec 04, 2014
Indian High Court Rules on Whether a U.S. Company's Liaison Office in India Constitutes a PE
Dec 02, 2014
U.S. IRS Issues Regulations for the Failure to Satisfy Gain Recognition Agreements Reporting Requirements
Nov 28, 2014
U.S. IRS Publishes Email Response Regarding Withholding Tax Implications for Interest Paid by a Foreign Disregarded Entity of a U.S. Corporation
Nov 25, 2014
TIEA between Ecuador and the U.S. to be Negotiated
Nov 21, 2014
US IRS Issues Priority Guidance Plan First Quarter Update
Nov 13, 2014
SSA between the U.S. and Uruguay under Negotiation
Nov 12, 2014
U.S. Legislation being Drafted to Increase REIT Ownership Threshold for FIRPTA Taxation
Nov 10, 2014
U.S. Treasury to Issue Additional Notices on Inversions and Earnings Stripping
Nov 06, 2014
IRS Issues Inflation Adjustments for Tax Year 2015
Nov 03, 2014
Multilateral Agreement on Information Exchange Signed by 51 Jurisdictions
Oct 30, 2014
U.S. Social Security Administration Issues 2015 Social Security Wage Cap and Rates
Oct 27, 2014
Switzerland Adopts Mandates for Global Automatic Exchange of Information Standard
Oct 09, 2014
Chile Approves Tax Treaty with the U.S.
Oct 06, 2014
New TIEA between Brazil and the U.S. Signed
Sep 25, 2014
U.S. Court of Appeals Rejects Methods Used in Determining Hypothetical Royalties
Sep 24, 2014
U.S. Treasury Takes Action Against Inversions
Sep 23, 2014
Norway Has Terminated Inheritance Tax Treaties With Switzerland and the U.S.
Sep 23, 2014
U.S. Senators Introduce Anti-Inversion Bill "Pay What You Owe Before You Go Act"
Sep 19, 2014
TIEA between Mauritius and the United States has Entered into Force
Sep 17, 2014
CRS Provides an Overview of U.S. Inversion Issues and Potential Legislative and Administrative Actions
Sep 09, 2014
U.S. Interest Rates on Overpaid and Underpaid Tax Remain Unchanged for Q4
Sep 04, 2014
U.S. IRS Seeks Public Comment on Withholding Tax Reporting Forms 1042, 1042–S, and 1042–T
Sep 04, 2014
U.S. Treasury has Published List of Boycott Countries
Aug 28, 2014
Protocol to the TIEA between the U.S. and Gibraltar has Entered into Force
Aug 19, 2014
Germany Formalizes FATCA Obligations
Aug 11, 2014
Stop Corporate Earnings Stripping Act of 2014 Discussion Draft Released
Aug 07, 2014
U.S. IRS Posts Updated FAQs on the FATCA Registration System and the FFI List
Aug 05, 2014
Social Security Agreement between the U.S. and Switzerland has Entered into Force
Aug 01, 2014
U.S. Legislators Introduce 'No Federal Contracts for Corporate Deserters Act'
Jul 30, 2014
U.S. Senate to Vote on Onshoring Bill
Jul 24, 2014
IRS Issues Memorandum on Withholding Tax when a Beneficial Owner Claims Exemption but Fails to Include the Relevant Income in Their Tax Return
Jul 16, 2014
Anti-Inversion Amendment Passed by U.S. House of Representatives
Jul 16, 2014
Protocol to the TIEA between the U.S. and Gibraltar Signed
Jul 09, 2014
Guernsey Ratifies Protocol to the TIEA with the U.S.
Jul 08, 2014
FATCA in Effect
Jul 03, 2014
Spain Approves Protocol to Tax Treaty with the U.S.
Jul 01, 2014
U.S. Employer Tax Credit Bill Announced
Jun 27, 2014
TIEA between Hong Kong and the U.S. has Entered into Force
Jun 26, 2014
Short-Term U.S. Tax Haven Abuse Measure Approved for 2015
Jun 12, 2014
U.S. Senators Call for Profit Repatriation Holiday
Jun 11, 2014
IRS Adopts "Taxpayer Bill of Rights"
Jun 10, 2014
U.S. Interest Rates on Overpaid and Underpaid Tax Remain Unchanged for Q3
Jun 09, 2014
Protocol to TIEA between the U.S. and Liechtenstein Signed
Jun 05, 2014
IRS Releases Draft Schedule N (Form 1120) for Foreign Operations of U.S. Corporations
Jun 03, 2014
Update - U.S. Anti-Inversion Bill
May 21, 2014
New Tax Treaty between the U.S. and Poland sent to the U.S. Senate
May 21, 2014
U.S. Anti-Inversion Bill Expected Soon
May 16, 2014
Bill Introduced to U.S. House of Representatives for CFC Dividend Exclusion
May 14, 2014
FATCA Search and Download Tool to Launch June 2014
May 13, 2014
"In Use" is the Key when Determining a PE due to an Installation or Structure in India
May 12, 2014
Australia Court Rules on Application of Tax Treaty Provisions for Offshore Partnerships with U.S. Resident Partners
May 12, 2014
TIEA between Colombia and the U.S. has Entered Into Force
May 12, 2014
Protocol to the Tax Treaty between the U.S. and Spain sent to the U.S. Senate
May 09, 2014
Hong Kong to Implement TIEA with the U.S.
May 07, 2014
Proposed U.S. House Bill Would Permanently Extend Subpart F Exception
Apr 23, 2014
FATCA Agreements in Substance will be Considered in Effect
Apr 04, 2014
U.S. Approves New Tax Treaty with Hungary
Apr 04, 2014
U.S. Approves New Tax Treaty with Chile
Apr 04, 2014
U.S. Approves New Tax Treaty with Hungary
Apr 04, 2014
U.S. Approves New Tax Treaty with Chile
Apr 04, 2014
U.S. Court Rejects IRS's Transfer Pricing Adjustment
Apr 03, 2014
Severance Payments Must be Taxed Says U.S. Supreme Court
Mar 31, 2014
U.S. Issues Notice on the Treatment of Virtual Currency
Mar 28, 2014
U.S. Interest Rates on Overpayment and Underpayment Unchanged for Q2
Mar 17, 2014
US Tax Court allows deduction for captive insurance premiums
Jan 01, 2014
Regulations issued on IRS reporting requirements for US shareholders of PFICs and other foreign corporations
Jan 01, 2014
Loss deductions disallowed for lack of economic substance
Dec 31, 2013
Regulations issued regarding withholding on payment of dividend equivalents from US sources
Dec 31, 2013
Treaty between India and US – Indian decision on taxability of payments made for standard training services as fees for technical services
Dec 31, 2013
Treaty between India and United States – Indian decision on whether payment for use of software was a royalty
Dec 31, 2013
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Dec 25, 2013
US Tax Court denies tax deduction for qualified domestic production activities with regard to direct mail advertising
Dec 25, 2013
US Senate Finance Committee releases proposals for cost recovery and tax accounting rules
Dec 25, 2013
US Senate Finance Committee releases proposals for international business tax reform
Dec 25, 2013
Treaty between Finland and United States – Finnish domestic treatment granted to a US company's PE in Finland due to non-discrimination principle
Dec 25, 2013
Treaty between United States and Mexico – US District Court denies summary judgment with regard to residence of dual resident taxpayer
Dec 25, 2013
IRS issues Memorandum on cross-border reorganization transactions
Dec 02, 2013
Treaty between India and United States – Indian decision that similar business activities do not give rise to a PE
Dec 02, 2013
Treaty between India and United States – Indian decision on attribution of profits arising from services rendered to head office
Dec 02, 2013
US Tax Court reduces deductible amount of repatriated CFC earnings based on transfer pricing adjustments
Dec 02, 2013
US Tax Court allows interest deduction for loan that was part of transaction lacking economic substance
Dec 02, 2013
Proposed regulations issued regarding limitations on loss importation
Dec 02, 2013
US Tax Court disallows tax benefits from cross-border leasing transactions
Nov 12, 2013
White House issues proposals for simplifying tax code and creating jobs and economic growth
Nov 12, 2013
Treaty between India and United States – Indian decision on when fixed place is "at the disposal" of the non-resident company and the manner of computing profits attributable to a PE
Nov 12, 2013
Treaty between US and Belgium – IRS releases text of competent authority agreement on application of AOA
Nov 12, 2013
US Court of Appeals disallows favourable dividend treatment for Subpart F income
Sep 16, 2013
1970 Treaty between Belgium and US – Belgian Supreme Court decides that reduction of tax credit for foreign interest by multiplication with a debt financing coefficient is compatible with treaty
Sep 16, 2013
Treaty between Russia and US – Russian MoF clarifies tax treatment applicable to interest that may qualify as dividends
Sep 16, 2013
Decision that internal TNMM is preferred over external TNMM
Jul 29, 2013
US, Australia, and UK announce plan to share data to combat offshore tax evasion
Jun 27, 2013
US Senate Finance Committee issues paper on international tax reform options
Jun 27, 2013
Treaty between Australia and United States – Australian Federal Court holds Cayman Islands partnership not US resident and cannot be assessed under the treaty
Jun 27, 2013
Multilateral action between United Kingdom, France, Germany, Italy and Spain to counter tax evasion
Jun 24, 2013
Indian decision that arm's length adjustment is allowable for advertisement and marketing expenses
Jun 24, 2013
Tax benefits from structured financial transaction denied for lack of economic substance
Jun 24, 2013
US Tax Court reclassifies loan structure as dividend payments
Jun 24, 2013
US Federal Court of Appeals affirms denial of loss deduction for lack of economic substance
Jun 24, 2013
Regulations issued on property transfers and stock distributions in cross-border reorganizations
Jun 24, 2013
2014 Budget – President submits Administration's proposals to Congress with tax changes for businesses
Jun 24, 2013
2014 Budget – President submits Administration's proposals to Congress with international tax changes
Jun 24, 2013
India-US tax treaty and India-Ireland tax treaty – Indian decision that a website does not by itself constitute a PE
Jun 24, 2013
Treaty between India and United States – Indian decision that transfer of shares without consideration is not prima facie a tax avoidance scheme
Jun 24, 2013
Treaty between US and Switzerland – image right payments are exempt from US tax as royalties
Jun 24, 2013
Indian decision on source of royalty paid between non-resident companies
May 06, 2013
Swiss bank sentenced for US tax evasion schemes
May 06, 2013
Treaty between Belgium and United States – clarifying circular published
May 04, 2013
Treaty between India and United States – Indian decision that taxability of business income on presumptive basis is subject to presence of PE
May 04, 2013
Treaty between US and Norway – IRS releases competent authority agreement regarding fiscally transparent entities
May 04, 2013
Treaty between United States and Poland – signing announced and details
May 04, 2013
US UPREIT is a capture foreign collective investment vehicle
Mar 25, 2013
Swiss bank enters guilty plea for US tax evasion schemes
Mar 25, 2013
Final regulations issued to prevent tax-avoidance in stock acquisitions by related corporations
Mar 25, 2013
Legislation enacted to avert fiscal cliff
Mar 25, 2013
American Taxpayer Relief Act signed into law
Mar 25, 2013
Treaty between United States and Japan – texts of protocol and exchange of notes released
Mar 25, 2013
Treaty between United States and Spain – text of protocol and MOU released
Mar 25, 2013
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Feb 09, 2013
IRS Chief Counsel issues memorandum on electronic submission of withholding certificates
Feb 09, 2013
Transactions with foreign corporations reduce possessions tax credit
Dec 02, 2012
IRS Chief Counsel issues memorandum on ETI exclusion for purposes of subpart F income
Dec 02, 2012
US Court of Appeals for Fifth Circuit requires disclosure of foreign accounts under Bank Secrecy Act
Dec 02, 2012
Netherlands to sign agreement with the US with respect to FATCA
Dec 02, 2012
Public comments requested on US foreign tax credit treatment of certain foreign dividends
Dec 02, 2012
Public comments requested on FIRPTA tax incident to corporate reorganizations and distributions
Dec 02, 2012
Public comments requested on IRS forms for transfers of US real property under FIRPTA
Dec 02, 2012
Advance agreements between related parties properly characterized as equity
Oct 23, 2012
Temporary regulations issued regarding payment of dividend equivalents from US sources
Oct 23, 2012
UK-US FATCA agreement signed
Oct 23, 2012
Regulations issued on integrated hedging transactions
Oct 23, 2012
US Court of Appeals affirms retrospective global interest netting for tax underpayments and tax overpayments
Oct 14, 2012
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Oct 14, 2012
Treaty between US and Canada – IRS releases competent authority agreement regarding application of Authorized OECD Approach (AOA)
Oct 14, 2012
Final regulations issued on treatment of overall foreign and domestic losses (OFLs and ODLs) for FTC limitation
Sep 03, 2012
Relief provided under PFIC rules for foreign banks holding government bonds
Sep 03, 2012
Proposed regulations issued on high-taxed passive income and OFL recapture for FTC limitation
Sep 03, 2012
Treaty between India and United States – Indian decision on the sale of copyrighted software is not in the nature of royalties
Sep 03, 2012
US Court of Appeals allows FTC for UK windfall tax
Jul 29, 2012
Foreign entity's advance to its US subsidiary characterized as loan
Jul 29, 2012
Final regulations issued on surrogate foreign corporations in offshore inversion transactions
Jul 29, 2012
Regulations issued on substantial business activities in offshore inversion transactions
Jul 29, 2012
IRS issues drafts of revised withholding certificates for foreign beneficial owners
Jul 29, 2012
US taxpayer's investment in foreign entity re-characterized as loan
Jul 25, 2012
US Court of Federal Claims: position of taxpayer upheld under FSC regime
Jul 25, 2012
Regulations issued regarding upfront payments made by CFC under NPC
Jul 25, 2012
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Jun 21, 2011
2012 Budget – President submits to Congress
Mar 30, 2011
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Feb 28, 2011
Treaty between Malta and United States enters into force
Jan 09, 2011
Protocol to treaty between New Zealand and United States enters into force
Jan 09, 2011
US Congress enacts FTC and other international tax reforms
Sep 06, 2010
Treaty between Spain and US – Spanish National Court holds payments for software subject to 10% withholding tax (general rate for "other royalties")
Jul 17, 2010
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Jun 13, 2010
2011 Budget – President submits to Congress
Mar 23, 2010
Treaty between Chile and United States – details
Mar 23, 2010
Protocol to treaty between United States and France enters into force
Jan 20, 2010
Treaty between Italy and US enters into force
Jan 20, 2010
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Dec 21, 2009
Protocol to treaty between Switzerland and United States – details
Oct 11, 2009
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Aug 13, 2009
RS issues industry directive regarding Section 965 dividend received deduction and Section 482 transfer pricing adjustments
Jul 16, 2009
Protocol to treaty between France and United States submitted for ratification
Jul 16, 2009
Protocol to treaty between Luxembourg and United States – details
Jul 16, 2009
Protocol to treaty between Switzerland and United States initialed
Jul 16, 2009
Treaty between United States and Hungary – negotiations
Jul 16, 2009
Protocol to treaty between US and New Zealand referred to US Senate
Jul 16, 2009
Protocol to treaty between Luxembourg and United States signed
Jun 07, 2009
IRS releases updated version of Publication 901 on US income tax treaties
Jun 07, 2009
Switzerland
May 13, 2009
IRS issues updated Publication 515 for withholding of tax on non-resident aliens and foreign entities
May 13, 2009
US
May 13, 2009
US economic stimulus bill: business provisions
Apr 10, 2009
Protocol and MoU to treaty between United States and France signed – details
Feb 22, 2009
Treaty between United States and Malta referred to US Congress for ratification
Feb 22, 2009
Memorandum of Understanding signed between US and German competent authorities
Feb 22, 2009
Final regulations issued to add Bulgarian Aktsionerno Druzhestvo to US check-the-box per se corporation list
Jan 23, 2009
Protocol to treaty between New Zealand and United States – details
Jan 23, 2009
Treaty and protocol between United States and Bulgaria enter into force
Jan 23, 2009
Protocol between United States and Canada enters into force
Jan 23, 2009
Treaty between United States and Iceland enters into force
Jan 23, 2009
Treaty between Australia and United States – ATO rules payments for hire of substantial equipment not subject to withholding tax
Dec 24, 2008
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
Dec 24, 2008
IRS extends relief period for investments by CFCs in US debt obligations
Nov 04, 2008
US-Bulgaria income tax treaty and protocol ratified by US
Nov 04, 2008
Protocol to treaty between United States and Canada ratified
Nov 04, 2008
Treaty between United States and Iceland ratified
Nov 04, 2008
OECD released 2008 Model Tax Convention
Oct 07, 2008
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
Oct 07, 2008
2001 treaty between United States and United Kingdom – IRS issues interpretation of Art. 18 (Pension Schemes)
Oct 07, 2008
Discussion draft on New Art. 7 of OECD Model – details
Aug 30, 2008
Treaty between India and US – Indian ruling that monthly payments for bandwidth charges treated as business profits, not royalty or fees for included services
Aug 30, 2008
Fifth protocol to treaty between US and Canada – US Technical Explanation published
Aug 30, 2008
Treaty between US and Bulgaria – US Technical Explanation published
Aug 30, 2008
Treaty between US and Iceland – US Technical Explanation published
Aug 30, 2008
Treaty between United States and Malta - details
Aug 30, 2008
OECD Council approves 2008 Model Tax Convention
Aug 11, 2008
Final regulations issued to curb FTC abuses
Aug 11, 2008
Protocol to treaty between Bulgaria and US ratified
Aug 11, 2008
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.
Aug 11, 2008
Treaty between Germany and United States – German Federal Financial Court rules on non-deductibility of losses from US (non-EU/EEA) PE
Aug 11, 2008
Comments on draft contents of 2008 update to Model Tax Convention published
Jul 27, 2008
Final regulations regarding partnership allocations to look-through entities or members of consolidated group
Jul 27, 2008
Bulgarian Income Tax Treaty and Protocol referred to US Senate
Jul 27, 2008
Treaty between US and Iceland – referred to US Senate Committee on Foreign Relations
Jun 21, 2008
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
Jun 21, 2008
Tax treaty between Canada and US – US Tax Court rules AMT FTC limitation prevails over treaty
Jun 21, 2008
Protocol to treaty between US and Germany – IRS issues interim guidance re mandatory arbitration procedure
Jun 21, 2008
Treaty between United States and Malta initialled
Jun 21, 2008
US announces negotiations for new protocol with New Zealand
Jun 21, 2008
IRS issues Chief Counsel Advice on recapture of dual consolidated losses
May 14, 2008
US check-the-box regulations updated to add Bulgarian entity to per se corporation list
May 14, 2008
Treaty between Australia and US – No treaty relief for US tax paid
May 14, 2008
Indian decision on software licensing
May 14, 2008
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
May 14, 2008
Protocol to US-Canada treaty referred to US Senate Committee on Foreign Relations
May 14, 2008
Treaty between US and Bulgaria – details
Apr 15, 2008
Protocol to treaty between US and Canada transmitted to US Senate for consent to ratify
Apr 15, 2008
Treaty between US and Malta – negotiations
Apr 15, 2008
IRS publishes Chief Counsel Advice on reasonable cause requests with respect to dual consolidated losses
Mar 16, 2008
Protocol to treaty between Bulgaria and US signed
Mar 16, 2008
Indian decision on taxability of payments made to US credit rating agency
Mar 16, 2008
US
Mar 16, 2008
OECD released discussion draft on transactional profit methods
Feb 08, 2008
IRS issues updated procedures for private letter rulings and other guidance from IRS National Office
Feb 08, 2008
Treaty between India and the United States – Indian decision on existence of PE re computerized reservation system
Feb 08, 2008
Treaty between Russia and United States – Russian Ministry of Finance clarifies application of treaty re deduction of certain expenses incurred for purposes of PE
Feb 08, 2008
Treaty between United States and Belgium enters into force
Feb 08, 2008
Tax Executives Institute submits comments to US Treasury Department on new US-Canada protocol
Feb 08, 2008
Protocol to treaty between United States and Denmark enters into force
Feb 08, 2008
Protocol to treaty between United States and Finland enters into force
Feb 08, 2008
The new protocol to the income tax treaty between the United States and Germany, signed on 1 June 2006, entered into force on 28 December 2007. The announcement was made in Treasury Department release hp-753 dated 2 January 2008. The new protocol applies from 1 January 2007 for withholding taxes, from 1 January 2008 for other taxes, and in respect of taxes on capital on items owned on or after 1 January 2008.
Feb 08, 2008
US Treasury Department releases report on study of US tax treaties
Jan 16, 2008
Canada completes steps required to give effect to the fifth protocol to the Canada-US income tax treaty
Jan 16, 2008
Treaty between India and the United States – Indian Revenue clarifies availability of dispute settlement benefits in
Jan 16, 2008
Treaty between United States and Mexico – IRS to evaluate whether Mexican impuesto empresarial a tasa única qualifies for US tax credit
Jan 16, 2008
Treaty between United States and Belgium ratified
Jan 16, 2008
Protocol to treaty between United States and Denmark ratified by US Senate
Jan 16, 2008
Protocol to treaty between United States and Finland ratified by US Senate
Jan 16, 2008
Protocol to treaty between United States and Germany ratified
Jan 16, 2008
IRS makes revisions in proposed FTC regulations
Dec 03, 2007
Treaty between Iceland and United States – details
Dec 03, 2007
Regulations to Netherlands-US tax treaty published in the Netherlands (withholding tax reduction or refund)
Dec 03, 2007
Treaty between United States and Belgium approved
Dec 03, 2007
Protocol to treaty between United States and Denmark approved
Dec 03, 2007
Protocol to treaty between United States and Finland approved
Dec 03, 2007
Protocol to treaty between United States and Germany approved
Dec 03, 2007
IRS releases text of US-UK mutual agreement on definition of "first notification" under US-UK income tax treaty
Dec 03, 2007
Fifth protocol to treaty between Canada and US – details
Nov 04, 2007
Treaty between Iceland and United States signed
Nov 04, 2007
Treasury Department and IRS issues final regulations eliminating country-by-country reporting by US RICs
Oct 01, 2007
Treaty between Australia and US – ATO explains treaty shopping
Oct 01, 2007
Final regulations issued for determination of earnings and profits attributable to stock of CFCs
Sep 02, 2007
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Sep 02, 2007
US
Sep 02, 2007
Indian Supreme Court decision on whether captive BPO activities give rise to PE and income attributable to PE on such activities
Sep 02, 2007
New agreement on organizations eligible for benefits under Art. 35 of Netherlands-US treaty signed
Sep 02, 2007
Treasury Department reissues list of international boycott countries that result in restriction of US tax benefits
Jul 29, 2007
Belgian abolition of fixed FTC incompatible with tax treaty between Belgium and US
Jul 29, 2007
German Lower Court
Jul 29, 2007
US Senate hearings on new treaty and protocol between Belgium and US
Jul 29, 2007
US Senate hearings on protocol to treaty between Denmark and US
Jul 29, 2007
US Senate hearings on protocol to treaty between Finland and US
Jul 29, 2007
US Senate hearings on protocol to treaty between Germany and US
Jul 29, 2007
Treasury Department released statement on attribution of profits under Authorized OECD Approach (AOA)
Jul 02, 2007
Non-discrimination and group income elections
Jul 02, 2007
US court orders IRS summons enforced under US-Mexico income tax treaty
Jul 02, 2007
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Jun 18, 2007
Treaty between Australia and United States – US tax debts not enforceable in
Jun 18, 2007
Treaty between Belgium and US ratified
Jun 18, 2007
Italian tax authorities interpret application of Art. 15 of EU-Swiss Agreement
Jun 18, 2007
Revised Commentary on Article 7 of OECD Model released
May 28, 2007
Final regulations issued on US withholding exemption for portfolio interest received by foreign persons
May 28, 2007
Proposed regulations issued to curb foreign tax credit abuses
May 28, 2007
Tax treaty between Australia and United States – Australia's Federal Court rejects tax treaty override
May 28, 2007
IRS issues fact sheet on reporting requirements for foreign financial accounts
Apr 28, 2007
Treaty between United States and Bulgaria signed
Apr 28, 2007
US
Apr 28, 2007
Indian ruling on classification of income of Canadian and US foreign institutional investors making portfolio investments in India
Mar 24, 2007
Final Report on Improving the Resolution of Tax Treaty Disputes
Mar 24, 2007
Treaty between United States and Japan – US court dismisses claims for relief for information exchanged under treaty
Mar 24, 2007
Report on Attribution of Profits to PEs released
Feb 24, 2007
China signs first APA with US
Feb 24, 2007
Supreme Court of Thailand treats payment for US customer base as royalty
Feb 24, 2007
Treasury Department reissues list of international boycott countries that result in restriction of US tax benefits
Feb 24, 2007
New treaty between Belgium and US signed
Jan 15, 2007
Indian decision finds payments for use of satellite transponder not "royalty"
Jan 15, 2007
Treaties with the United States and Canada considered
Jan 15, 2007
IRS updates list of treaty countries with corporations qualified to pay dividends eligible for reduced US tax rates
Dec 17, 2006
Protocol to treaty between Denmark and US
Dec 17, 2006
New protocol to France-US income tax treaty ratified
Nov 12, 2006
Treaty between Iceland and United States – negotiations concluded
Nov 12, 2006
Thailand
Nov 12, 2006
UK–US treaty agreement on dual consolidated losses
Nov 12, 2006
Exchange of information treaty between US and Isle of Man enters into force
Nov 12, 2006
IRS announces new user fee for issuing US residency certificates
Oct 14, 2006
Proposed regulations issued on exclusion of previously taxed income of controlled foreign corporations
Oct 14, 2006
Ruling on taxability of non-resident with captive BPOs to be appealed
Oct 14, 2006
Regulations issued on tax treatment of foreign persons from residual interests in US REMICs
Sep 12, 2006
Proposed regulations issued on taxpayers eligible to claim US foreign tax credit
Sep 12, 2006
Protocol to treaty between Finland and United States presented to Finnish parliament
Sep 12, 2006
Tax treaty between Italy and US – Italian ruling on concept of beneficial owner (royalties)
Sep 12, 2006
Protocol amending treaty between US and Sweden enters into force
Sep 12, 2006
Exchange of information agreement between Isle of Man and US – implementation
Aug 13, 2006
US
Aug 13, 2006
US Senate may hold hearings on new Denmark, Finland, and Germany protocols
Aug 13, 2006
New US model tax treaty expected in 2006
Aug 13, 2006
Proposed regulations issued for determination of earnings and profits attributable to stock of CFCs under IRC Sec. 1248
Jul 11, 2006
Australian treatment of shipping and aircraft leasing profits of UK and US enterprises
Jul 11, 2006
Australian Taxation Office denies interest withholding tax exemption to US financial institution
Jul 11, 2006
ATO denies interest withholding tax exemption to a US pension fund
Jul 11, 2006
Indian decision on applicability of tax treaty or domestic tax rate for different income streams
Jul 11, 2006
Thin capitalization rules not applicable to interest paid by Italian PE to US head office; deductibility of interest expense under transfer pricing rules analyzed
Jul 11, 2006
US Treasury Department announces signing of protocol to US-Finland income tax treaty
Jul 11, 2006
US Treasury Department announces signing of protocol to US-Germany income tax treaty
Jul 11, 2006
IRS issues notices with guidance for income from international shipping and air operations
Jun 14, 2006
Treaty between Australia and US – ATO explains its understanding of LoB article
Jun 14, 2006
Protocol to treaty between US and Denmark signed
Jun 14, 2006
Availability of US dependent territories' tax information to Australian tax authorities
May 14, 2006
US Senate ratifies protocols to income and capital, and estate, inheritance and gift, tax treaties between France and US
May 14, 2006
IRS releases list of qualified investment banks under MoU defining investment bank for interest withholding under 2003 Japan-US treaty
May 14, 2006
US Senate ratifies protocol to treaty between Sweden and US
May 14, 2006
Ruling on taxability of non-residents with captive BPOs
Apr 09, 2006
Status of Irish common contractual funds under the Ireland-US tax treaty
Apr 09, 2006
US Foreign Relations Committee approves protocols to income and capital, and estate, inheritance and gift, tax treaties between France and US
Apr 09, 2006
US and Spain enter mutual agreement on treatment of LLCs, disregarded entities, and Sub-S corporations under treaty and protocol
Apr 09, 2006
US Foreign Relations Committee approves protocol to treaty between Sweden and US
Apr 09, 2006
Final regulations issued on classification of business entities organized in multiple jurisdictions
Mar 16, 2006
Treaty negotiations – update
Mar 16, 2006
US
Mar 16, 2006
US Senate hearings on protocol to treaty between Sweden and US
Mar 16, 2006
IRS updates procedure for APAs in transfer pricing cases
Feb 19, 2006
Following a reduction in withholding tax rates in the 2001 protocol to the Australia-US tax treaty, Australia is required under the most-favoured-nation clause in its existing treaty with Korea (Rep.) to renegotiate the 1982 Australia-Korea (Rep.) treaty.
Feb 19, 2006
Indian ruling that US pension fund does not qualify for treaty benefits
Feb 19, 2006
The Competent Authorities of Canada and the United States have signed a memorandum of understanding (MOU) setting out the principles, guidelines and procedures to be followed in resolving factual disagreements in mutual agreement cases under the 1980 US-Canada income tax treaty. The MOU was signed on 23 December 2005 and follows the MOU signed on 3 June 2005 that formalized the mutual agreement procedure (MAP) for resolving cases of double taxation under the treaty. It also follows the announcement by the US Internal Revenue Service (IRS) and the Canada Revenue Agency (CRA) on 8 December 2005 that they had reached agreement on procedures for resolving factual disputes in the MAP process.
Feb 19, 2006
The US Tax Court has disallowed a deduction for a contribution to a French pension plan and payment of French real estate taxes. Isabelle Bichindaritz v. Commissioner of Internal Revenue (T.C. Memo 2005-298 dated 29 December 2005). The case involved a French citizen who was teaching at a US university. She claimed a deduction on her US tax return for a contribution to a French pension plan and also a deduction for the payment of French real estate taxes.
Feb 19, 2006
The Competent Authorities of the United States and Japan have signed a memorandum of understanding (MOU) defining the term "investment bank" for purposes of Art. 11 (Interest) of the 2003 income tax treaty between the two countries. The definition is relevant for determining eligibility for zero-rate withholding for interest payments under Art. 11(3)(c)(i) of the 003 Japan-US Treaty. The MOU was signed on 27 December 2005 and released by the US Internal Revenue Service (IRS) on 28 December 2005.
Feb 19, 2006
US and Mexico sign revised mutual agreement on eligibility of fiscally transparent entities to claim treaty benefits
Feb 19, 2006
US Court
Feb 19, 2006
The amending protocol to the France-US income and capital tax treaty of 31 August 1994 4 were submitted to the French Parliament on 14 December 2005.
Jan 01, 2006
Spanish Supreme Court examines refund of excess amounts withheld non-discrimination provision (US treaty)
Jan 01, 2006
Presidential tax reform panel issues final report
Dec 06, 2005
On 23 November 2005, Sweden ratified the new protocol to the Sweden-United States Income Tax Treaty of 1 September 1994, signed on 30 September 2005, by way of Law SFS 1994:1617 published in the Svensk Frfattningssamling (official publication of statutes in Sweden).
Dec 06, 2005
Details of the protocol signed by Sweden and the United States on 30 September 2005 to the Sweden-United States income tax treaty of 1 September 1994 have become available. The protocol provides for a zero withholding tax in respect of inter-company dividends. The application of the zero rate essentially requires that (i) the beneficial owner is a company resident of the other contracting state that has owned, directly or indirectly, through one or more residents of either contracting states, shares representing 80% or more of the voting power in the company paying the dividends for at least a 12-month period ending on the date on which the entitlement to the dividends is determined and (ii) certain conditions under the tax treaty's limitation-on-benefits clause are met. Under certain conditions, pension funds are also eligible for the zero rate.
Nov 09, 2005
Final and proposed regulations issued on taxation of earnings of CFCs
Oct 16, 2005
On 30 September 2005 Sweden and the United States signed a protocol to the Sweden-United states income tax treaty of 1 September 1994. Further details of the protocol will be reported subsequently.
Oct 16, 2005
US and Mexico reach mutual agreement on eligibility of fiscally transparent entities to claim treaty benefits
Oct 16, 2005
The Netherlands State Secretary for Finance published Decree IFZ2005/546M on 6 July 2006 concerning the application of the 1992 income tax treaty between The Netherlands-United States to hybrid entities.
Aug 03, 2005
The Internal Revenue Service (IRS) has released the text of a private letter ruling (PLR) on 3 June 2005 holding that stock of a US corporation owned by a UK company through foreign entities that elect to be treated as disregarded entities under the US check-the-box regulations can qualify for the zero dividend withholding rate under
Aug 03, 2005
The US Treasury Department has announced that the protocol to the 1984 income tax treaty between the United States and Barbados, signed on 14 July 2004, entered into force on 20 December 2004. According to the Treasury Department announcement, the protocol will generally effective for taxable years beginning on or after 1 January 2005, and the provisions of the protocol relating to withholding taxes applies for amounts paid or credited on or after 1 February 2005.
Jan 19, 2005
The protocol of 8 March 2004 to the 1992 income tax treaty between the United States and the Netherlands entered into force on 28 December 2004. The protocol will generally be effective for taxable periods beginning on or after 1 January 2005, and the provisions of the protocol relating to withholding taxes will be effective for amounts paid or credited on or after 1 February 2005. Persons that were entitled to greater benefits under the US-Netherlands treaty before it was modified by the protocol of 8 March 2004 may elect for the application of the old provisions for a period of 12 months from the date on which the protocol provisions became effective.
Jan 19, 2005
The protocol has been ratified by both states but has not yet entered into force. However, it is expected that the exchange of ratification instruments will take place timely as a result of which the protocol will be effective as from 1 January 2005.
Sep 07, 2004