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United States Tax News

White House issues proposals for simplifying tax code and creating jobs and economic growth

12 November 2013
Treaty between India and United States – Indian decision on when fixed place is "at the disposal" of the non-resident company and the manner of computing profits attributable to a PE

12 November 2013
Treaty between US and Belgium – IRS releases text of competent authority agreement on application of AOA

12 November 2013
US Tax Court disallows tax benefits from cross-border leasing transactions

12 November 2013
Treaty between Russia and US – Russian MoF clarifies tax treatment applicable to interest that may qualify as dividends

16 September 2013
US Court of Appeals disallows favourable dividend treatment for Subpart F income

16 September 2013
1970 Treaty between Belgium and US – Belgian Supreme Court decides that reduction of tax credit for foreign interest by multiplication with a debt financing coefficient is compatible with treaty

16 September 2013
Decision that internal TNMM is preferred over external TNMM

29 July 2013
Treaty between Australia and United States – Australian Federal Court holds Cayman Islands partnership not US resident and cannot be assessed under the treaty

27 June 2013
US, Australia, and UK announce plan to share data to combat offshore tax evasion

27 June 2013
US Senate Finance Committee issues paper on international tax reform options

27 June 2013
Treaty between US and Switzerland – image right payments are exempt from US tax as royalties

24 June 2013
US Federal Court of Appeals affirms denial of loss deduction for lack of economic substance

24 June 2013
India-US tax treaty and India-Ireland tax treaty – Indian decision that a website does not by itself constitute a PE

24 June 2013
US Tax Court reclassifies loan structure as dividend payments

24 June 2013
Tax benefits from structured financial transaction denied for lack of economic substance

24 June 2013
Indian decision that arm's length adjustment is allowable for advertisement and marketing expenses

24 June 2013
Multilateral action between United Kingdom, France, Germany, Italy and Spain to counter tax evasion

24 June 2013
2014 Budget – President submits Administration's proposals to Congress with tax changes for businesses

24 June 2013
Treaty between India and United States – Indian decision that transfer of shares without consideration is not prima facie a tax avoidance scheme

24 June 2013
2014 Budget – President submits Administration's proposals to Congress with international tax changes

24 June 2013
Regulations issued on property transfers and stock distributions in cross-border reorganizations

24 June 2013
Swiss bank sentenced for US tax evasion schemes

6 May 2013
Indian decision on source of royalty paid between non-resident companies

6 May 2013
Treaty between Belgium and United States – clarifying circular published

4 May 2013
Treaty between United States and Poland – signing announced and details

4 May 2013
Treaty between India and United States – Indian decision that taxability of business income on presumptive basis is subject to presence of PE

4 May 2013
Treaty between US and Norway – IRS releases competent authority agreement regarding fiscally transparent entities

4 May 2013
Legislation enacted to avert fiscal cliff

25 March 2013
Swiss bank enters guilty plea for US tax evasion schemes

25 March 2013
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