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United States Tax News

Comments on draft contents of 2008 update to Model Tax Convention published

27 July 2008
Protocol to treaty between US and Germany – IRS issues interim guidance re mandatory arbitration procedure

21 June 2008
Tax treaty between Canada and US – US Tax Court rules AMT FTC limitation prevails over treaty

21 June 2008
Treaty between US and Iceland – referred to US Senate Committee on Foreign Relations

21 June 2008
US announces negotiations for new protocol with New Zealand

21 June 2008
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

21 June 2008
Treaty between United States and Malta initialled

21 June 2008
US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

14 May 2008
Protocol to US-Canada treaty referred to US Senate Committee on Foreign Relations

14 May 2008
IRS issues Chief Counsel Advice on recapture of dual consolidated losses

14 May 2008
US check-the-box regulations updated to add Bulgarian entity to per se corporation list

14 May 2008
Indian decision on software licensing

14 May 2008
Treaty between Australia and US – No treaty relief for US tax paid

14 May 2008
Treaty between US and Malta – negotiations

15 April 2008
Treaty between US and Bulgaria – details

15 April 2008
Protocol to treaty between US and Canada transmitted to US Senate for consent to ratify

15 April 2008
US

16 March 2008
Protocol to treaty between Bulgaria and US signed

16 March 2008
IRS publishes Chief Counsel Advice on reasonable cause requests with respect to dual consolidated losses

16 March 2008
Indian decision on taxability of payments made to US credit rating agency

16 March 2008
Treaty between India and the United States – Indian decision on existence of PE re computerized reservation system

8 February 2008
Treaty between Russia and United States – Russian Ministry of Finance clarifies application of treaty re deduction of certain expenses incurred for purposes of PE

8 February 2008
OECD released discussion draft on transactional profit methods

8 February 2008
IRS issues updated procedures for private letter rulings and other guidance from IRS National Office

8 February 2008
Treaty between United States and Belgium enters into force

8 February 2008
Protocol to treaty between United States and Denmark enters into force

8 February 2008
Tax Executives Institute submits comments to US Treasury Department on new US-Canada protocol

8 February 2008
Protocol to treaty between United States and Finland enters into force

8 February 2008
The new protocol to the income tax treaty between the United States and Germany, signed on 1 June 2006, entered into force on 28 December 2007. The announcement was made in Treasury Department release hp-753 dated 2 January 2008. The new protocol applies from 1 January 2007 for withholding taxes, from 1 January 2008 for other taxes, and in respect of taxes on capital on items owned on or after 1 January 2008.

8 February 2008
Treaty between India and the United States – Indian Revenue clarifies availability of dispute settlement benefits in

16 January 2008
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