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United States Tax News

UK-US FATCA agreement signed

23 October 2012
Advance agreements between related parties properly characterized as equity

23 October 2012
Temporary regulations issued regarding payment of dividend equivalents from US sources

23 October 2012
US Court of Appeals affirms retrospective global interest netting for tax underpayments and tax overpayments

14 October 2012
Treaty between US and Canada – IRS releases competent authority agreement regarding application of Authorized OECD Approach (AOA)

14 October 2012
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

14 October 2012
Treaty between India and United States – Indian decision on the sale of copyrighted software is not in the nature of royalties

3 September 2012
Final regulations issued on treatment of overall foreign and domestic losses (OFLs and ODLs) for FTC limitation

3 September 2012
Relief provided under PFIC rules for foreign banks holding government bonds

3 September 2012
Proposed regulations issued on high-taxed passive income and OFL recapture for FTC limitation

3 September 2012
Foreign entity's advance to its US subsidiary characterized as loan

29 July 2012
Final regulations issued on surrogate foreign corporations in offshore inversion transactions

29 July 2012
IRS issues drafts of revised withholding certificates for foreign beneficial owners

29 July 2012
US Court of Appeals allows FTC for UK windfall tax

29 July 2012
Regulations issued on substantial business activities in offshore inversion transactions

29 July 2012
Regulations issued regarding upfront payments made by CFC under NPC

25 July 2012
US Court of Federal Claims: position of taxpayer upheld under FSC regime

25 July 2012
US taxpayer's investment in foreign entity re-characterized as loan

25 July 2012
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

21 June 2011
2012 Budget – President submits to Congress

30 March 2011
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

28 February 2011
Protocol to treaty between New Zealand and United States enters into force

9 January 2011
Treaty between Malta and United States enters into force

9 January 2011
US Congress enacts FTC and other international tax reforms

6 September 2010
Treaty between Spain and US – Spanish National Court holds payments for software subject to 10% withholding tax (general rate for "other royalties")

17 July 2010
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

13 June 2010
Treaty between Chile and United States – details

23 March 2010
2011 Budget – President submits to Congress

23 March 2010
Protocol to treaty between United States and France enters into force

20 January 2010
Treaty between Italy and US enters into force

20 January 2010
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