Orbitax

United States Tax News

Exchange of information treaty between US and Isle of Man enters into force

12 November 2006

Thailand

12 November 2006

Ruling on taxability of non-resident with captive BPOs to be appealed

14 October 2006

IRS announces new user fee for issuing US residency certificates

14 October 2006

Proposed regulations issued on exclusion of previously taxed income of controlled foreign corporations

14 October 2006

Protocol amending treaty between US and Sweden enters into force

12 September 2006

Protocol to treaty between Finland and United States presented to Finnish parliament

12 September 2006

Regulations issued on tax treatment of foreign persons from residual interests in US REMICs

12 September 2006

Tax treaty between Italy and US – Italian ruling on concept of beneficial owner (royalties)

12 September 2006

Proposed regulations issued on taxpayers eligible to claim US foreign tax credit

12 September 2006

US Senate may hold hearings on new Denmark, Finland, and Germany protocols

13 August 2006

New US model tax treaty expected in 2006

13 August 2006

Exchange of information agreement between Isle of Man and US – implementation

13 August 2006

US

13 August 2006

US Treasury Department announces signing of protocol to US-Germany income tax treaty

11 July 2006

Indian decision on applicability of tax treaty or domestic tax rate for different income streams

11 July 2006

Australian treatment of shipping and aircraft leasing profits of UK and US enterprises

11 July 2006

Proposed regulations issued for determination of earnings and profits attributable to stock of CFCs under IRC Sec. 1248

11 July 2006

ATO denies interest withholding tax exemption to a US pension fund

11 July 2006

US Treasury Department announces signing of protocol to US-Finland income tax treaty

11 July 2006

Thin capitalization rules not applicable to interest paid by Italian PE to US head office; deductibility of interest expense under transfer pricing rules analyzed

11 July 2006

Australian Taxation Office denies interest withholding tax exemption to US financial institution

11 July 2006

IRS issues notices with guidance for income from international shipping and air operations

14 June 2006

Protocol to treaty between US and Denmark signed

14 June 2006

Treaty between Australia and US – ATO explains its understanding of LoB article

14 June 2006

IRS releases list of qualified investment banks under MoU defining investment bank for interest withholding under 2003 Japan-US treaty

14 May 2006

US Senate ratifies protocols to income and capital, and estate, inheritance and gift, tax treaties between France and US

14 May 2006

Availability of US dependent territories' tax information to Australian tax authorities

14 May 2006

US Senate ratifies protocol to treaty between Sweden and US

14 May 2006

Status of Irish common contractual funds under the Ireland-US tax treaty

9 April 2006

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