Searching Content indexed under Tax Treaties by Morrison & Foerster LLP ordered by Published Date Descending.
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The UK Double Tax Treaty Passport Scheme – Changes For The UK Loan Market
The UK Double Tax Treaty Passport ("DTTP") scheme has recently been extended by HM Revenue & Customs ("HMRC") to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme.
10 Jul 2017
Tax Talk: Volume 10, Issue 1
We held up Tax Talk this quarter in order to bring you the latest on the Trump administration's tax reform plans.
United States
15 May 2017
European M+A News - Winter 2016
Inbound investment structures seeking to acquire a German or UK corporation should take into account the potential taxation of both the local entity and the shareholder.
European Union
16 Feb 2016
Tax Talk Volume 7, No. 1 April 2014
We can’t think of a better way to end Q1 2014 than by bringing you the year’s first issue of Tax Talk.
United States
29 Apr 2014
Treasury Releases FATCA Intergovernmental Model Agreements
The U.S. Treasury Department released two model agreements that reflect the intergovernmental approach outlined in Treasury's February joint statement with France, Germany, Italy, Spain, and the United Kingdom.
United States
15 Aug 2012
U.S. Treasury And Japan/Switzerland Announce They Will Negotiate Toward A Third Way For FATCA Compliance
As we have previously reported, the Foreign Account Tax Compliance Act ("FATCA") is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope.
United States
29 Jun 2012
IRS Issues Final Regulations Requiring Reporting Of Deposit Interest Paid To Non-Resident Aliens
On April 17, 2012, the Internal Revenue Service (the "IRS") issued final regulations requiring financial institutions to report to the IRS any payments of interest on deposits maintained at an office in the U.S. made to non-resident aliens who are residents of certain countries with which the U.S. has entered into exchange of information agreements.
United States
26 Apr 2012
Are You Ready For March 18, 2012 —A Key Date In The U.S. Taxation Of Cross-Border Financing Transactions
We have previously discussed the significance of March 18, 2012 as the effective date of certain cross-border tax provisions included in the Foreign Account Tax Compliance Act ("FATCA"). FATCA was enacted on March 18, 2010 as part of the Hiring Incentives to Restore Employment Act.
United States
6 Mar 2012
Treasury Publishes Highly Anticipated "Withholdable Payment" FATCA Regulations And Outlines International Cooperation Alternative
After months of waiting, the Treasury Department ("Treasury") released proposed Foreign Account Tax Compliance Act ("FATCA") "withholdable payment" regulation on February 8, 2012.
United States
21 Feb 2012
New Proposed Regulations Clarify Scope of Section 892 and Create De Minimis Exception for Inadvertent Commercial Activity
On November 2, 2011, the Internal Revenue Service (the "IRS") and the Treasury Department issued proposed Treasury Regulations (the "Proposed Regulations")1 which modify and clarify the temporary Treasury Regulations promulgated in 1988 (the "Temporary Regulations") under Section 892 of the Internal Revenue Code of 1986, as amended (the "Code")
United States
10 Nov 2011
MoFo New York Tax Insights Volume 2, Issue 6
Many issues that arise during the course of a New York State tax audit have long troubled both taxpayers and the Audit Division: from the taxpayer side, lengthy and delayed audits, voluminous or duplicative Information Document Requests ("IDRs").
United States
9 Jun 2011
Relief from UK Withholding Tax and the New Passport Scheme
On 1 September 2010, the new Double Taxation Treaty Passport ("DTTP") scheme became operative. According to Her Majesty’s Revenue & Customs ("HMRC") the new scheme will result in expedited treaty clearances and will provide a simpler and more efficient method of paying interest to overseas lenders, which has been sought after by businesses as an alternative to the present certified claim procedure for some time.
United States
9 Sep 2010
Foreign Account Tax Compliance Act Of 2009 – Congress Sets Its Sights On Overseas Tax Evasion
On October 27, 2009, Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York), chairmen of the Congressional tax writing committees, introduced the Foreign Account Tax Compliance Act of 2009 (the “Bill”) in the U.S. Congress.
United States
8 Nov 2009
IRS Announces Additional Revisions To “Anti-Inversion” Regulations Under Code Section 7874
On September 17, 2009, the Internal Revenue Service (“IRS”) issued Notice 2009-78 (“Notice”) announcing its intention to issue additional regulations under the “anti-inversion” rules of Section 7874 of the Internal Revenue Code of 1986, as amended (“Code”).
United States
4 Oct 2009
IRS Revises "Anti-Inversion" Regulations Under Code Section 7874
On June 9, 2009, the IRS issued new final and temporary regulations (T.D. 9453) under the "anti-inversion"; rules of Section 7874 of Internal Revenue Code of 1986, as amended (the "Code").
United States
1 Jul 2009
Administration Issues General Explanation Of Its Fiscal Year 2010 Revenue Proposals, Including International Provisions
On May 11, the Obama Administration (the "Administration") issued general explanations of its Fiscal Year 2010 revenue proposals, including a number of international tax reform proposals that could have a dramatic impact on multinational businesses and other taxpayers with foreign investments or activities.
United States
28 May 2009
New Tax Legislation Includes Important Amendments Affecting Regulated Investment Companies (Mutual Funds), Including Their Investments In Real Estate Investment Trusts (REITs)
On May 17, 2006, President Bush signed into law H.R. 4297, the “Tax Increase Prevention and Reconciliation Act,” (the “Act”), a $70 billion tax package that will extend the reduced individual 15 percent tax rate on certain dividends and long-term capital gains from the end of 2008 through December 31, 2010. The Act increases the alternative minimum tax exemption levels for 2006 and extends provisions permitting small businesses to expense up to $100,000 in investments in depreciable assets for
United States
31 May 2006
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