News & Analysis as of

Tax Treaty

Tax Court Denies Treaty Benefit To Canadian Post–Doctoral Fellow

by Fox Rothschild LLP on

In a case of first impression, the Tax Court held that the U.S.–Canada Tax Treaty (Treaty) did not exempt a Canadian citizen from U.S. income tax on the unemployment compensation she received from the State of Ohio. Pei Fang...more

September 2017: An Update on UK Tax Disputes Including the New UK Corporate Criminal Offense: What Is It and What Should You Do...

Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more

Investor-Friendly Tax Treaty Set for Mexico and Spain

by Jones Day on

The Situation: A Tax Treaty developed to avoid double taxation, negotiated between Mexico and Spain in late 2015, was just recently published in the official gazettes of both nations. The new protocols are effective September...more

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

Tax treaty interpretation

by Hogan Lovells on

On 31 August 2017, the Dutch Court of Appeals of 's-Hertogenbosch issued judgment in a case dealing with the application of the most-favoured-nation (MFN) clause contained in the Netherlands/South Africa Double Tax Agreement...more

Swiss-Domiciled Company Denied Treaty Benefits For Treaty Shopping

by Fox Rothschild LLP on

Statutory Background- When a foreign corporation receives dividends from U.S. sources, the income is generally subject to tax at 30%. To avoid double taxation and encourage cross-border investments, the U.S. has entered...more

Disallowance of Deduction for Interest Paid to Hungarian Affiliate Serves as a Reminder of Department’s Continued Audit Scrutiny...

by Reed Smith on

A case recently resolved at the Appellate Tax Board serves as a reminder that Massachusetts’ auditors continue to aggressively challenge the following intercompany transactions: - Interest deductions for interest paid to...more

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

Protocol Amending the Mexico–Belgium Tax Treaty Published

by Jones Day on

On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion ("Tax Treaty") between Belgium and Mexico was published in Mexico's Official Journal...more

Ireland's Revenue releases guidelines on requesting Mutual Agreement Procedure assistance

by DLA Piper on

Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as...more

Japan Legal Update - Volume 27 | July 2017

by Jones Day on

On June 7, 2017, Japan signed the "Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting" ("MLI"). The MLI is a part of the OECD/G20 base erosion and profit-shifting...more

Tax Planning for Investment Into the United States Through Hybrid Entities - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more

Impact of the Multilateral Instrument on U.S. Taxpayers

by Alston & Bird on

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all...more

The UK Double Tax Treaty Passport Scheme – Changes for the UK Loan Market

by Morrison & Foerster LLP on

The UK Double Tax Treaty Passport (“DTTP”) scheme has recently been extended by HM Revenue & Customs (“HMRC”) to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme. The aim of the amendments is...more

Inbound and Outbound U.S. Tax Planning - What's Left After the MLI?

by Bilzin Sumberg on

On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place. ...more

BEPS Update: OECD Multilateral Instrument Signed

by Proskauer - Tax Talks on

On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS),...more

More than 60 countries sign OECD multilateral convention to counter base erosion and profit shifting

by DLA Piper on

This week's signing ceremony for the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS marks a new and important milestone in the international tax agenda to tackle perceived abusive...more

Do You know that the US might have a Tax Sharing Information Agreement with your Country?

by Foodman CPAs & Advisors on

The US has Tax treaties and Tax Information Exchange Agreements (TIEAs) with certain countries that provide, upon request, for the exchange of U.S. income information regarding their citizens or residents. There are...more

IRS Announces Tax Treaties Resulted in Low Withholding Rates to Foreign Individuals and Entities

In the 2017 Statistics of Income Bulletin, the IRS reported that foreign recipients of U.S. source income from treaty countries had an average withholding rate of 13.9% compared to 25.6% for payments made to residents of...more

Extensions to the double tax treaty passport scheme

by DLA Piper on

The double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under...more

Bank of Italy Smooths the Path for Direct Debt Investment into Italy via EU Alternative Investment Funds

by McDermott Will & Emery on

International investment funds are set to benefit from measures issued by the Bank of Italy, aimed at facilitating direct investment into the country by EU alternative investment funds....more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Ukraine ratifies the Double Tax Treaty with Luxembourg and a Free Trade Zone Agreement with Canada (Ukrainian)

by Dentons on

On 14 March 2017 the Ukrainian Parliament passed two laws for On 14 March 2017 the Ukrainian Parliament passed two laws for ratification of two important international treaties...more

Ukraine ratifies the Double Tax Treaty with Luxembourg and a Free Trade Zone Agreement with Canada

by Dentons on

On 14 March 2017 the Ukrainian Parliament passed two laws for ratification of two important international treaties...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

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