Income Tax Treaty Internal Revenue Service

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Planning For Qualified Dividend Income When Taking Foreign Companies Public - Tax Update Volume 2015, Issue 2

Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income...more

IRS proposes changes to Competent Authority and APA procedures: comments requested by 3/20/2014

The IRS has published for comment two draft revenue procedures that change the existing process for US taxpayers requesting Competent Authority relief under the Mutual Agreement Procedures (MAP) and other provisions of US...more

Favorable IRS ruling for US taxpayer on application of US - Cyprus tax treaty

In a recent internal legal memorandum (the ILM), the IRS concluded that a US individual was entitled to treat dividends received from a Cypriot holding company with no Cypriot ownership as qualified dividend income (QDI), and...more

When Is A Statutory Benefit A ‘Treaty Benefit’? When IRS Says So!

Since Section 1(h)(11) was enacted as part of the Jobs and Growth Tax Relief Reconciliation Act of 2003, questions have been raised on exactly how to interpret the section's legislative history. Under this provision, a...more

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