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United States Tax News

Loss deductions disallowed for lack of economic substance

31 December 2013
Treaty between India and United States – Indian decision on whether payment for use of software was a royalty

31 December 2013
Regulations issued regarding withholding on payment of dividend equivalents from US sources

31 December 2013
US Senate Finance Committee releases proposals for international business tax reform

25 December 2013
Treaty between Finland and United States – Finnish domestic treatment granted to a US company's PE in Finland due to non-discrimination principle

25 December 2013
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

25 December 2013
US Senate Finance Committee releases proposals for cost recovery and tax accounting rules

25 December 2013
US Tax Court denies tax deduction for qualified domestic production activities with regard to direct mail advertising

25 December 2013
Treaty between United States and Mexico – US District Court denies summary judgment with regard to residence of dual resident taxpayer

25 December 2013
US Tax Court reduces deductible amount of repatriated CFC earnings based on transfer pricing adjustments

2 December 2013
Proposed regulations issued regarding limitations on loss importation

2 December 2013
US Tax Court allows interest deduction for loan that was part of transaction lacking economic substance

2 December 2013
IRS issues Memorandum on cross-border reorganization transactions

2 December 2013
Treaty between India and United States – Indian decision that similar business activities do not give rise to a PE

2 December 2013
Treaty between India and United States – Indian decision on attribution of profits arising from services rendered to head office

2 December 2013
White House issues proposals for simplifying tax code and creating jobs and economic growth

12 November 2013
Treaty between India and United States – Indian decision on when fixed place is "at the disposal" of the non-resident company and the manner of computing profits attributable to a PE

12 November 2013
Treaty between US and Belgium – IRS releases text of competent authority agreement on application of AOA

12 November 2013
US Tax Court disallows tax benefits from cross-border leasing transactions

12 November 2013
Treaty between Russia and US – Russian MoF clarifies tax treatment applicable to interest that may qualify as dividends

16 September 2013
US Court of Appeals disallows favourable dividend treatment for Subpart F income

16 September 2013
1970 Treaty between Belgium and US – Belgian Supreme Court decides that reduction of tax credit for foreign interest by multiplication with a debt financing coefficient is compatible with treaty

16 September 2013
Decision that internal TNMM is preferred over external TNMM

29 July 2013
Treaty between Australia and United States – Australian Federal Court holds Cayman Islands partnership not US resident and cannot be assessed under the treaty

27 June 2013
US, Australia, and UK announce plan to share data to combat offshore tax evasion

27 June 2013
US Senate Finance Committee issues paper on international tax reform options

27 June 2013
Treaty between US and Switzerland – image right payments are exempt from US tax as royalties

24 June 2013
US Federal Court of Appeals affirms denial of loss deduction for lack of economic substance

24 June 2013
India-US tax treaty and India-Ireland tax treaty – Indian decision that a website does not by itself constitute a PE

24 June 2013
US Tax Court reclassifies loan structure as dividend payments

24 June 2013
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