US: Public comments requested on branch profits tax for foreign corporations
The US Treasury Department and the Internal Revenue Service (IRS) are requesting comments concerning regulations TD 8223 (Branch Tax), TD 8432 (Branch Profits Tax) and TD 8657 (Regulations on Effectively Connected Income and the Branch Profits
See MoreUS: Report on advance pricing agreements
The US report on advance pricing agreements issued on 25 March 2013 covers the activities of the program in 2012. At the beginning of 2012 the APA program was merged with the office of the competent authority (USCA) that is responsible for the
See MoreUS: IRS invites public comments on Bilateral Safe Harbors for Certain Transfer Pricing Issues
The Internal Revenue Service (IRS) announced on March 15, 2013, that it is consulting interested parties on the development of a model memorandum of understanding (MOU) between Competent Authorities relating to transfer pricing safe harbors for
See MoreUS: IRS Announces Interest Rates on tax overpayments and underpayments for 2013 second quarter.
The US Internal Revenue Service has issued Revenue Ruling 2013-6 with the announcement of the interest rates on tax overpayments and tax underpayments for the calendar quarter beginning 1 April 2013. The rate will remain the same as in the previous
See MoreUnited States: IRS publishes quarterly list of individuals who have expatriated.
The US Internal Revenue Service has published a quarterly notice with a list of US citizens and long-term US residents who have renounced their citizenship or residency for US federal tax purposes. The Notice is dated 29 January 2013, and is based
See MoreTreaty between US and Poland signed
United States has signed an Income Tax Treaty (2013) with Poland on 13 February 2013 which will replace the existing agreement, signed 1974. The new treaty provides for reductions in withholding taxes on cross-border payments of dividends,
See MoreCanada begins negotiations with the United States towards a Protocol
The Canadian government announced on November 8, 2012, that it had begun negotiations with the United States towards a Protocol to their double taxation agreement (DTA) to enhance the countries' capacity to exchange tax
See MoreUnited States and Belgium have agreed to expand the scope of their DTA
The US tax authority, the Internal Revenue Service, announced on August 20, 2012, that the United States and Belgium have agreed to expand the scope of their 2006 double taxation agreement (DTA) to also include taxes imposed at municipal level in
See MoreCanada: welcomes IRS tax return help
Canadian Finance Minister has welcomed the US government's decision to help dual citizens residing in Canada deal with their US tax filing obligations. The Internal Revenue Service (IRS) will also offer assistance to those with Canadian retirement
See MoreUS President forwards DTA between Chile and the United States to the Senate
On 17th May 2012, United States President Barack Obama forwarded the pending double taxation agreement (DTA) signed between Chile and the United States on February 4, 2010, to the Senate as part of the ratification procedures necessary to bring the
See MoreUS Senate Passes Highways Tax Bill
On March 14, 2012, the United States Senate passed, on a bipartisan basis, a bill to provide for an extension of highway-related taxes and the funding of infrastructural spending by the Federal Highway Trust Fund (FHTF), which included an anti-tax
See MoreUS: IRS has new online tool for “Lower-Paid Taxpayers”
As part of its effort to improve service to taxpayers, the United States Internal Revenue Service (IRS) has announced the availability of a new online tool to help taxpayers to find more easily a location for volunteer tax preparation
See MoreAnnulment of contractors’ tax by US
The United States Congress has finally approved a legislation to repeal the 3% withholding tax on payments made to contractors providing services to government entities. The bill was passed in the House of Representatives on a bipartisan vote. When
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