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United States Tax News

Tax benefits from structured financial transaction denied for lack of economic substance

24 June 2013
Indian decision that arm's length adjustment is allowable for advertisement and marketing expenses

24 June 2013
Multilateral action between United Kingdom, France, Germany, Italy and Spain to counter tax evasion

24 June 2013
2014 Budget – President submits Administration's proposals to Congress with tax changes for businesses

24 June 2013
Treaty between India and United States – Indian decision that transfer of shares without consideration is not prima facie a tax avoidance scheme

24 June 2013
2014 Budget – President submits Administration's proposals to Congress with international tax changes

24 June 2013
Regulations issued on property transfers and stock distributions in cross-border reorganizations

24 June 2013
Swiss bank sentenced for US tax evasion schemes

6 May 2013
Indian decision on source of royalty paid between non-resident companies

6 May 2013
Treaty between Belgium and United States – clarifying circular published

4 May 2013
Treaty between United States and Poland – signing announced and details

4 May 2013
Treaty between India and United States – Indian decision that taxability of business income on presumptive basis is subject to presence of PE

4 May 2013
Treaty between US and Norway – IRS releases competent authority agreement regarding fiscally transparent entities

4 May 2013
Legislation enacted to avert fiscal cliff

25 March 2013
Swiss bank enters guilty plea for US tax evasion schemes

25 March 2013
Treaty between United States and Spain – text of protocol and MOU released

25 March 2013
US UPREIT is a capture foreign collective investment vehicle

25 March 2013
Final regulations issued to prevent tax-avoidance in stock acquisitions by related corporations

25 March 2013
Treaty between United States and Japan – texts of protocol and exchange of notes released

25 March 2013
American Taxpayer Relief Act signed into law

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

9 February 2013
IRS Chief Counsel issues memorandum on electronic submission of withholding certificates

9 February 2013
US Court of Appeals for Fifth Circuit requires disclosure of foreign accounts under Bank Secrecy Act

2 December 2012
Public comments requested on FIRPTA tax incident to corporate reorganizations and distributions

2 December 2012
Transactions with foreign corporations reduce possessions tax credit

2 December 2012
Netherlands to sign agreement with the US with respect to FATCA

2 December 2012
IRS Chief Counsel issues memorandum on ETI exclusion for purposes of subpart F income

2 December 2012
Public comments requested on US foreign tax credit treatment of certain foreign dividends

2 December 2012
Public comments requested on IRS forms for transfers of US real property under FIRPTA

2 December 2012
Regulations issued on integrated hedging transactions

23 October 2012
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