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United States Tax News

OECD released 2008 Model Tax Convention

7 October 2008
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

7 October 2008
Treaty between India and US – Indian ruling that monthly payments for bandwidth charges treated as business profits, not royalty or fees for included services

30 August 2008
Treaty between US and Iceland – US Technical Explanation published

30 August 2008
Treaty between US and Bulgaria – US Technical Explanation published

30 August 2008
Fifth protocol to treaty between US and Canada – US Technical Explanation published

30 August 2008
Treaty between United States and Malta - details

30 August 2008
Discussion draft on New Art. 7 of OECD Model – details

30 August 2008
Treaty between Germany and United States – German Federal Financial Court rules on non-deductibility of losses from US (non-EU/EEA) PE

11 August 2008
Final regulations issued to curb FTC abuses

11 August 2008
On 10 July 2008, the Minister of Finance indicated Canada's agreement with the US Treasury Department's technical explanation to the fifth protocol to the Canada-US tax treaty. Canada ratified the protocol on 14 December 2007, when Bill S-2 received Royal Assent.

11 August 2008
OECD Council approves 2008 Model Tax Convention

11 August 2008
Protocol to treaty between Bulgaria and US ratified

11 August 2008
Bulgarian Income Tax Treaty and Protocol referred to US Senate

27 July 2008
Final regulations regarding partnership allocations to look-through entities or members of consolidated group

27 July 2008
Comments on draft contents of 2008 update to Model Tax Convention published

27 July 2008
Protocol to treaty between US and Germany – IRS issues interim guidance re mandatory arbitration procedure

21 June 2008
Tax treaty between Canada and US – US Tax Court rules AMT FTC limitation prevails over treaty

21 June 2008
Treaty between US and Iceland – referred to US Senate Committee on Foreign Relations

21 June 2008
US announces negotiations for new protocol with New Zealand

21 June 2008
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

21 June 2008
Treaty between United States and Malta initialled

21 June 2008
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

14 May 2008
Protocol to US-Canada treaty referred to US Senate Committee on Foreign Relations

14 May 2008
IRS issues Chief Counsel Advice on recapture of dual consolidated losses

14 May 2008
US check-the-box regulations updated to add Bulgarian entity to per se corporation list

14 May 2008
Indian decision on software licensing

14 May 2008
Treaty between Australia and US – No treaty relief for US tax paid

14 May 2008
Treaty between US and Malta – negotiations

15 April 2008
Treaty between US and Bulgaria – details

15 April 2008
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