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United States Tax News

Regulations issued regarding upfront payments made by CFC under NPC

25 July 2012
US Court of Federal Claims: position of taxpayer upheld under FSC regime

25 July 2012
US taxpayer's investment in foreign entity re-characterized as loan

25 July 2012
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

21 June 2011
2012 Budget – President submits to Congress

30 March 2011
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

28 February 2011
Protocol to treaty between New Zealand and United States enters into force

9 January 2011
Treaty between Malta and United States enters into force

9 January 2011
US Congress enacts FTC and other international tax reforms

6 September 2010
Treaty between Spain and US – Spanish National Court holds payments for software subject to 10% withholding tax (general rate for "other royalties")

17 July 2010
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

13 June 2010
Treaty between Chile and United States – details

23 March 2010
2011 Budget – President submits to Congress

23 March 2010
Protocol to treaty between United States and France enters into force

20 January 2010
Treaty between Italy and US enters into force

20 January 2010
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

21 December 2009
Protocol to treaty between Switzerland and United States – details

11 October 2009
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

13 August 2009
Protocol to treaty between Switzerland and United States initialed

16 July 2009
Protocol to treaty between US and New Zealand referred to US Senate

16 July 2009
Protocol to treaty between Luxembourg and United States – details

16 July 2009
RS issues industry directive regarding Section 965 dividend received deduction and Section 482 transfer pricing adjustments

16 July 2009
Treaty between United States and Hungary – negotiations

16 July 2009
Protocol to treaty between France and United States submitted for ratification

16 July 2009
Protocol to treaty between Luxembourg and United States signed

7 June 2009
IRS releases updated version of Publication 901 on US income tax treaties

7 June 2009
IRS issues updated Publication 515 for withholding of tax on non-resident aliens and foreign entities

13 May 2009
US

13 May 2009
Switzerland

13 May 2009
US economic stimulus bill: business provisions

10 April 2009
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