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United States Tax News

Protocol to the Tax Treaty between the U.S. and Spain sent to the U.S. Senate

9 May 2014
Hong Kong to Implement TIEA with the U.S.

7 May 2014
Proposed U.S. House Bill Would Permanently Extend Subpart F Exception

23 April 2014
U.S. Approves New Tax Treaty with Chile

4 April 2014
U.S. Approves New Tax Treaty with Chile

4 April 2014
U.S. Approves New Tax Treaty with Hungary

4 April 2014
FATCA Agreements in Substance will be Considered in Effect

4 April 2014
U.S. Approves New Tax Treaty with Hungary

4 April 2014
U.S. Court Rejects IRS's Transfer Pricing Adjustment

3 April 2014
Severance Payments Must be Taxed Says U.S. Supreme Court

31 March 2014
U.S. Issues Notice on the Treatment of Virtual Currency

28 March 2014
U.S. Interest Rates on Overpayment and Underpayment Unchanged for Q2

17 March 2014
Regulations issued on IRS reporting requirements for US shareholders of PFICs and other foreign corporations

1 January 2014
US Tax Court allows deduction for captive insurance premiums

1 January 2014
Treaty between India and US – Indian decision on taxability of payments made for standard training services as fees for technical services

31 December 2013
Loss deductions disallowed for lack of economic substance

31 December 2013
Treaty between India and United States – Indian decision on whether payment for use of software was a royalty

31 December 2013
Regulations issued regarding withholding on payment of dividend equivalents from US sources

31 December 2013
US Senate Finance Committee releases proposals for international business tax reform

25 December 2013
Treaty between Finland and United States – Finnish domestic treatment granted to a US company's PE in Finland due to non-discrimination principle

25 December 2013
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

25 December 2013
US Senate Finance Committee releases proposals for cost recovery and tax accounting rules

25 December 2013
US Tax Court denies tax deduction for qualified domestic production activities with regard to direct mail advertising

25 December 2013
Treaty between United States and Mexico – US District Court denies summary judgment with regard to residence of dual resident taxpayer

25 December 2013
US Tax Court reduces deductible amount of repatriated CFC earnings based on transfer pricing adjustments

2 December 2013
Proposed regulations issued regarding limitations on loss importation

2 December 2013
US Tax Court allows interest deduction for loan that was part of transaction lacking economic substance

2 December 2013
IRS issues Memorandum on cross-border reorganization transactions

2 December 2013
Treaty between India and United States – Indian decision that similar business activities do not give rise to a PE

2 December 2013
Treaty between India and United States – Indian decision on attribution of profits arising from services rendered to head office

2 December 2013
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