Tax Treaty

News & Analysis as of

IRS Simplifies Rules for Participants in Canadian Plans – Or Does it?

Under the US-Canada Income Tax Treaty, U.S. taxpayers who participate in Canadian registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs) (the Canadian Plans) are not required to pay tax on...more

IRS Simplifies Procedures for Favorable Tax Treatment on RRSPs and RRIFs

The IRS has finally made it much easier for taxpayers who hold interests in either of two popular Canadian retirement plans—registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs)—to get...more

IRS Denies Treaty Benefits Despite Lack of Treaty Shopping

In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from...more

France, Luxembourg amend tax treaty, affecting investment structures of Luxembourg vehicles holding French real estate

The French and Luxembourg governments have signed a new amendment to the French-Luxembourg tax treaty that will significantly impact the investment structures involving Luxembourg vehicles holding French real estate assets....more

New Amendment To The France-Luxembourg Tax Treaty: Capital Gains On Sale Of Real Estate Entities Will Be Taxable In The State...

Based on the press release issued by the Luxembourg Ministry of Finance (MoF), the amendment allocates the right to tax capital gains realised upon the sale of stock, shares or other rights in companies, trusts or any other...more

Investment in French real estate: France-Luxembourg double tax treaty changes

On 5 September 2014, the Governments of France and Luxembourg signed an amendment to the France-Luxembourg treaty dated 1 April 1958 (the “Treaty”), which will have an impact in the future for certain investments in French...more

Editorial: Qualifying for Treaty Benefits Under the “Derivative Benefits” Article

Foreign persons are subject to U.S. federal income tax on a limited basis. Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on...more

Crackdown on Tax Treaty Abuses

Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies....more

Tax Newsletter - May/June 2014 (China & Hong Kong)

Editorial Note: Welcome to our redesigned Tax Newsletter. You will notice we have streamlined the publication and will now publish bi-monthly instead of quarterly. For major developments that may be highly...more

New judgment on tax treaty between Germany and the US

Hybrid US S-Corporation eligible for participation exemption. Refund practice of taxes withheld remains to be seen. In a recent judgment (file no. I R 48/12), the German Federal Fiscal Court has commented on Art. 1...more

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

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