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United States Tax News

Treaty between United States and Spain – text of protocol and MOU released

25 March 2013
US UPREIT is a capture foreign collective investment vehicle

25 March 2013
Final regulations issued to prevent tax-avoidance in stock acquisitions by related corporations

25 March 2013
Treaty between United States and Japan – texts of protocol and exchange of notes released

25 March 2013
American Taxpayer Relief Act signed into law

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

9 February 2013
IRS Chief Counsel issues memorandum on electronic submission of withholding certificates

9 February 2013
US Court of Appeals for Fifth Circuit requires disclosure of foreign accounts under Bank Secrecy Act

2 December 2012
Public comments requested on FIRPTA tax incident to corporate reorganizations and distributions

2 December 2012
Transactions with foreign corporations reduce possessions tax credit

2 December 2012
Netherlands to sign agreement with the US with respect to FATCA

2 December 2012
IRS Chief Counsel issues memorandum on ETI exclusion for purposes of subpart F income

2 December 2012
Public comments requested on US foreign tax credit treatment of certain foreign dividends

2 December 2012
Public comments requested on IRS forms for transfers of US real property under FIRPTA

2 December 2012
Regulations issued on integrated hedging transactions

23 October 2012
UK-US FATCA agreement signed

23 October 2012
Advance agreements between related parties properly characterized as equity

23 October 2012
Temporary regulations issued regarding payment of dividend equivalents from US sources

23 October 2012
US Court of Appeals affirms retrospective global interest netting for tax underpayments and tax overpayments

14 October 2012
Treaty between US and Canada – IRS releases competent authority agreement regarding application of Authorized OECD Approach (AOA)

14 October 2012
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

14 October 2012
Treaty between India and United States – Indian decision on the sale of copyrighted software is not in the nature of royalties

3 September 2012
Final regulations issued on treatment of overall foreign and domestic losses (OFLs and ODLs) for FTC limitation

3 September 2012
Relief provided under PFIC rules for foreign banks holding government bonds

3 September 2012
Proposed regulations issued on high-taxed passive income and OFL recapture for FTC limitation

3 September 2012
Foreign entity's advance to its US subsidiary characterized as loan

29 July 2012
Final regulations issued on surrogate foreign corporations in offshore inversion transactions

29 July 2012
IRS issues drafts of revised withholding certificates for foreign beneficial owners

29 July 2012
US Court of Appeals allows FTC for UK windfall tax

29 July 2012
Regulations issued on substantial business activities in offshore inversion transactions

29 July 2012
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