United States Tax News
Regulations issued on integrated hedging transactions
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
Final regulations issued on treatment of overall foreign and domestic losses (OFLs and ODLs) for FTC limitation
3 September 2012
Proposed regulations issued on high-taxed passive income and OFL recapture for FTC limitation
3 September 2012
Relief provided under PFIC rules for foreign banks holding government bonds
3 September 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
IRS issues drafts of revised withholding certificates for foreign beneficial owners
29 July 2012
Regulations issued on substantial business activities in offshore inversion transactions
29 July 2012
Foreign entity's advance to its US subsidiary characterized as loan
29 July 2012
US Court of Appeals allows FTC for UK windfall tax
29 July 2012
Final regulations issued on surrogate foreign corporations 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
Treaty between Malta and United States enters into force
9 January 2011
Protocol to treaty between New Zealand 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
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits
21 December 2009