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United States Tax News

Treaty between United States and Malta referred to US Congress for ratification

22 February 2009
Protocol and MoU to treaty between United States and France signed – details

22 February 2009
Memorandum of Understanding signed between US and German competent authorities

22 February 2009
Treaty and protocol between United States and Bulgaria enter into force

23 January 2009
Protocol between United States and Canada enters into force

23 January 2009
Treaty between United States and Iceland enters into force

23 January 2009
Protocol to treaty between New Zealand and United States – details

23 January 2009
Final regulations issued to add Bulgarian Aktsionerno Druzhestvo to US check-the-box per se corporation list

23 January 2009
Treaty between Australia and United States – ATO rules payments for hire of substantial equipment not subject to withholding tax

24 December 2008
Treaty between India and US (non-discrimination) – Indian decision on applicability of withholding tax on lease rentals paid to non-residents and deductibility of such payments for Indian tax purposes

24 December 2008
Protocol to treaty between United States and Canada ratified

4 November 2008
US-Bulgaria income tax treaty and protocol ratified by US

4 November 2008
IRS extends relief period for investments by CFCs in US debt obligations

4 November 2008
Treaty between United States and Iceland ratified

4 November 2008
2001 treaty between United States and United Kingdom – IRS issues interpretation of Art. 18 (Pension Schemes)

7 October 2008
OECD released 2008 Model Tax Convention

7 October 2008
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

7 October 2008
Treaty between India and US – Indian ruling that monthly payments for bandwidth charges treated as business profits, not royalty or fees for included services

30 August 2008
Treaty between US and Iceland – US Technical Explanation published

30 August 2008
Treaty between US and Bulgaria – US Technical Explanation published

30 August 2008
Fifth protocol to treaty between US and Canada – US Technical Explanation published

30 August 2008
Treaty between United States and Malta - details

30 August 2008
Discussion draft on New Art. 7 of OECD Model – details

30 August 2008
Treaty between Germany and United States – German Federal Financial Court rules on non-deductibility of losses from US (non-EU/EEA) PE

11 August 2008
Final regulations issued to curb FTC abuses

11 August 2008
On 10 July 2008, the Minister of Finance indicated Canada's agreement with the US Treasury Department's technical explanation to the fifth protocol to the Canada-US tax treaty. Canada ratified the protocol on 14 December 2007, when Bill S-2 received Royal Assent.

11 August 2008
OECD Council approves 2008 Model Tax Convention

11 August 2008
Protocol to treaty between Bulgaria and US ratified

11 August 2008
Bulgarian Income Tax Treaty and Protocol referred to US Senate

27 July 2008
Final regulations regarding partnership allocations to look-through entities or members of consolidated group

27 July 2008
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