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United States Tax News

Supreme Court of Thailand treats payment for US customer base as royalty

24 February 2007
New treaty between Belgium and US signed

15 January 2007
Indian decision finds payments for use of satellite transponder not "royalty"

15 January 2007
Treaties with the United States and Canada considered

15 January 2007
IRS updates list of treaty countries with corporations qualified to pay dividends eligible for reduced US tax rates

17 December 2006
Protocol to treaty between Denmark and US

17 December 2006
New protocol to France-US income tax treaty ratified

12 November 2006
Exchange of information treaty between US and Isle of Man enters into force

12 November 2006
UK–US treaty agreement on dual consolidated losses

12 November 2006
Thailand

12 November 2006
Treaty between Iceland and United States – negotiations concluded

12 November 2006
Ruling on taxability of non-resident with captive BPOs to be appealed

14 October 2006
Proposed regulations issued on exclusion of previously taxed income of controlled foreign corporations

14 October 2006
IRS announces new user fee for issuing US residency certificates

14 October 2006
Protocol amending treaty between US and Sweden enters into force

12 September 2006
Proposed regulations issued on taxpayers eligible to claim US foreign tax credit

12 September 2006
Regulations issued on tax treatment of foreign persons from residual interests in US REMICs

12 September 2006
Tax treaty between Italy and US – Italian ruling on concept of beneficial owner (royalties)

12 September 2006
Protocol to treaty between Finland and United States presented to Finnish parliament

12 September 2006
US Senate may hold hearings on new Denmark, Finland, and Germany protocols

13 August 2006
New US model tax treaty expected in 2006

13 August 2006
Exchange of information agreement between Isle of Man and US – implementation

13 August 2006
US

13 August 2006
US Treasury Department announces signing of protocol to US-Germany income tax treaty

11 July 2006
Indian decision on applicability of tax treaty or domestic tax rate for different income streams

11 July 2006
Australian treatment of shipping and aircraft leasing profits of UK and US enterprises

11 July 2006
ATO denies interest withholding tax exemption to a US pension fund

11 July 2006
Thin capitalization rules not applicable to interest paid by Italian PE to US head office; deductibility of interest expense under transfer pricing rules analyzed

11 July 2006
Australian Taxation Office denies interest withholding tax exemption to US financial institution

11 July 2006
Proposed regulations issued for determination of earnings and profits attributable to stock of CFCs under IRC Sec. 1248

11 July 2006
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