Tax Treaty

News & Analysis as of

The IBC Act – the building of a nation

Although nobody knew it at the time, the inception of the BVI’s International Business Company Act occurred at some point during the year 1976. Nobody now recalls the exact date, except that it was during the summer.It is...more

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more

Swiss Bank Pleads Guilty In Alleged Tax Evasion Conspiracy

On May 19, the DOJ announced that a Swiss bank pleaded guilty and entered into agreements with federal and state regulators to resolve a multi-year investigation into the bank’s alleged conspiracy to assist U.S. taxpayers in...more

"OECD Outlines Plans to Prevent Double-Tax Treaty Abuse"

On March 14, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on preventing double-tax treaty abuse (the Treaty Report). The OECD supplemented this release on March...more

Federal Ministry of Finance publishes model for future double tax treaties

Germany provides insight into its tax treaty negotiation policy. The German Federal Ministry of Finance has followed the lead of the United States, Austria and Belgium and has published a model double tax treaty for...more

"Notice 2013-78: IRS Proposes Revisions to Competent Authority Process"

On November 22, 2013, the IRS issued Notice 2013-78, which contains draft Revenue Procedures applicable to requests for competent authority (CA) assistance. The IRS requested comments by March 10, 2014. The Revenue Procedure...more

International Tax News - November 2013

US-SWISS VOLUNTARY DISCLOSURE PROGRAM: DEADLINES ARE LOOMING – SWISS BANKS NEED NOT PANIC, BUT MUST ACT SWIFTLY AND THOUGHTFULLY - The recently announced voluntary bank disclosure program between Switzerland and the...more

U.K.-Cayman IGA Signed

The United Kingdom (U.K.) has published an agreed intergovernmental agreement (IGA) with the Cayman Islands. The IGA was signed on 5th November and is intended to improve international tax compliance by providing for domestic...more

Mixing Oil and Vinegar - Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the Investment Return of...

Overview - Master Limited Partnerships are publicly traded partnerships. As of 2010, the market capitalization of MLPs was $220 billion. These publicly traded partnerships invest primarily in energy and associated...more

Tax Newsletter - Second Edition 2013: A Review Of PRC And Hong Kong Tax Developments

In This Issue: *CHINA: - HEADQUARTER AND BRANCHES VAT FILING UNDER THE VAT PILOT PROGRAM - FURTHER CLARIFICATION ON BENEFICIAL OWNERSHIP OF DIVIDENDS UNDER DTA WITH HONG KONG - PE ON SECONDMENT...more

G20 Representatives Strike Historic Agreement on Automatic Tax Information Exchange

Tax records will be shared around the world by 2015 as part of a G20 pledge to crack down on international tax evasion. China was the sole holdout until it agreed to the plan just days before the summit in St. Petersburg....more

What The New Tax Treaty With China Means For Those Who Have Bank Accounts In China

SAN FRANCISCO, CA,– China has now joined the U.S.’ efforts to combat tax evasion by entering into the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on August 27, 2013. The gravamen of this new...more

The 180-Day Rule for Canadian Visitors – Law or Legend?

How Many Days Can I Be in the United States? We get inquiries from time to time from seasonal “snowbirds,” as well as from sales personnel, account managers, and others who make frequent and/or lengthy trips to the United...more

OECD Launches Action Plan on Base Erosion and Profit Shifting

The OECD released its Action Plan on Base Erosion and Profit Shifting (BEPS) on Friday. The BEPS initiative was launched earlier this year at the request of the G20 to counter alleged abuses by multinational corporations to...more

OECD/G20 International Tax Reform: Potential Impact on Canadian Companies

Earlier today the OECD provided its Action Plan on Base Erosion and Profit Shifting to the G20, which contains 15 specific recommendations for international tax reform. The OECD expects the Action Plan to be largely completed...more

"International Taxation – OECD Reboot for the 21st Century"

Introduction - Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an ambitious action plan...more

Rewriting the Fundamentals of International Taxation: the OECD BEPS Action Plan

The Organization for Economic Co-operation and Development has released its ambitious action plan to address base-erosion and profit-shifting. If the political will exists to enact the changes envisaged by the action plan,...more

International Tax News - June 2013

In This Issue: New tax treaty boosts Netherlands for inbound Chinese investment; Germany: far-reaching compromise proposed re Tax Act 2013; and, Italy clarifies tax laws re air carriers. ...more

New Tax Treaty signed between The Netherlands and Mainland China

The Netherlands and China signed a new Tax Treaty for the Avoidance of Double Taxation and Prevention of Fiscal Evasion on 31 May. Once in effect (no earlier than 1 January 2014), it will replace the current tax treaty, which...more

A refocusing of national tax priorities

With a continuation of the general downturn in Government finances across much of Europe, greater efforts are being made to open up the tax base, to clamp down on evasion and reassess the most aggressive avoidance schemes....more

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