Searching Content from United States indexed under Tax Treaties ordered by Published Date Descending.
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Protocol Amending US/Swiss Tax Treaty Takes Effect
The protocol amending the United States Tax Treaty with Switzerland has been ratified by the United States and began to take effect as of 20 September 2019.
4 Oct 2019
New Guidelines On Tax Exemptions For Investments In Italian Real Estate Funds
Several recent rulings concerning the tax exemption applicable to institutional investors into Italian real estate investment funds ("*REIFs*")
United States
20 Sep 2019
The Weekly Hill Update - July 15, 2019
Below is the Federal Policy team's weekly preview, posted when Congress is in session
United States
20 Aug 2019
Global Tax Planning In A Pre-2018 World
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations:
United States
2 Aug 2019
Overview Of Spring Term 2019 Supreme Court Tax Decisions
In its 2019 Spring Term, the Supreme Court published five decisions regarding tax matters, three of which limit states' taxing authority.
United States
17 Jul 2019
IRS Issues Proposed Regulations Regarding Withholding Under Section 1446(f)
On May 7, 2019, the US Treasury Department and the Internal Revenue Service (the "IRS") released proposed regulations regarding Section 1446(f)
United States
15 Jul 2019
Senate To Vote On Tax Treaties
On June 25, the Senate Foreign Relations Committee approved protocols to four income tax treaties, clearing the way for the treaties to be considered by the full Senate.
United States
11 Jul 2019
The High-Tax Kickout: G.I.L.T.I. Or Not G.I.L.T.I.?
On June 21, the Treasury published proposed and final regulations under Code §951A. They address, inter alia, an expansion of the high-tax kickout exception applicable to Subpart F Income.
United States
11 Jul 2019
The OECD Releases 2017 Full Version Of Model Tax Convention
The document is intended to be used as a starting point for tax treaty negotiations between jurisdictions.
United States
4 Jul 2019
U.S. Assists Finland In Investigation Of Payment Cardholders For Unreported Income Via John Doe Summons - Will The Use Of LLCs And Trusts Conceal Their Identities?
On May 1, 2019, the United States Department of Justice announced that a U.S. federal court had authorized the Internal Revenue Service to serve a so-called "John Doe" summons to several U.S. financial institutions.
United States
22 May 2019
DOJ And IRS Seek Information On Finnish Individuals Using U.S. Payment Cards
The DOJ petitioned the U.S. District Court for the Western District of North Carolina to authorize IRS summonses to uncover the identities of Finnish residents using U.S.-issued payment cards in Finland.
United States
16 May 2019
Digital Tax Update: U.S. Legislators React To Unilateral Digital Tax Proposals
The French government estimates that the DST would raise approximately 500 million Euros per year.
United States
15 May 2019
The Danish Conduit Cases: A Landmark Ruling On Withholding Tax And Abuse Of Rights
In an alarming development for some private equity funds, the Court of Justice of the European Union (the CJEU) has issued two judgments in the combined N Luxembourg 1 (Case C-115/16),
United States
11 Apr 2019
More Permanent Establishments: The Dwindling Preparatory And Auxiliary Activities Exception
Nothing is certain in this world, except death and taxes – and even taxes are subject to change.
United States
11 Apr 2019
The I.R.S. Approach To Dependent Agent Status
When foreign corporations have certain activities in the U.S., the question often arises as to whether a taxable presence exists in the U.S. for Federal income tax purposes.
United States
11 Apr 2019
Private Client USA | 2019
U.S. domiciliaries are generally subject to U.S. Federal estate tax, gift tax and generation-skipping transfer tax (the "GST tax") in the same manner as U.S. citizens
United States
26 Mar 2019
U.S. Tax Laws: A Review Of 2018 And A Look Ahead To 2019
U.S. taxpayers will remember 2018 as the year spent coming to terms with the tax reform legislation enacted at the end of 2017, known as the Tax Cuts and Jobs Act (TCJA).
United States
15 Mar 2019
Who's Got The B.E.A.T.? A Playbook For Determining Applicable Taxpayers And Payments
Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities significantly reduced regular corporate income tax
United States
11 Mar 2019
Proposed Code §864(C)(8) Regulations Codify Tax On Gain From Sale Of Partnership Interest
Code §864(c)(8) was enacted on December 22, 2017, by Public Law 115-97 ("P.L. 115-97").
United States
8 Mar 2019
What Are The Tax Impacts Of Brexit?
Brexit—the formal departure of the United Kingdom (the UK) from the European Union (the EU), pursuant to the referendum held in the UK in June 2016—is imminent: the UK will cease to be a member of the EU on March 29, 2019.
7 Mar 2019
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