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Tax Treaty Internal Revenue Service Competent Authority (CA)

Fox Rothschild LLP

Swiss-Domiciled Company Denied Treaty Benefits For Treaty Shopping

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

Alston & Bird

IRS Unveils New Competent Authority Procedures

Alston & Bird on

In the recent Rev. Proc. 2015-40, the IRS describes updated competent authority procedures for taxpayers seeking certain U.S. treaty relief. The new procedures, effective for requests on or after October 30, 2015, supersede...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Implements Final Changes to Competent Authority Process"

On August 12, 2015, the IRS issued Rev. Proc. 2015-40, which revises the procedures for obtaining competent authority (CA) assistance concerning issues arising under U.S. income tax treaties. This revenue procedure replaces...more

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