Permanent Establishment Can Be Created Through Agency Relationship, IRS Official Says

The activities of companies that send agents into other countries to do business can create a permanent establishment for tax purposes even if the presence of agents does not…

U.S., 14 Other Nations Sign OECD, Council of Europe Agreement on Cooperation in Tax Matters

Fifteen countries, including the United States, May 27 signed an update to a 1988 multilateral pact on administrative cooperation in tax matters that aims to provide a legal framework for…

Major Concerns Expressed by NY State Bar Association over House-Passed Curb on Tax Treaty Abuse

The New York State Bar Association Tax Section May 22 said it had “substantial and serious reservations” about a provision in House-passed jobs legislation (H.R. 4849) intended to stop…

Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal

The government continues to wrestle with the question of how a $10 million asset threshold for those required to disclose uncertain tax positions under a new proposal will apply to…

Tax Treaty’s Application to IRA of U.S. Retiree Living in Switzerland Explained

The Internal Revenue Service Office of Chief Counsel, in a program manager technical advice memorandum (PMTA 2010-002) released May 11, examined…

Pace of Change in Cross-Border Transparency Initiatives Increasing, IRS Official Says

The pace of change in the new world of increased transparency and information exchange has “accelerated on all fronts,” Internal Revenue Service Deputy Associate Chief Counsel (International) Theodore…

Tax Accords with Malta, New Zealand Sent to Senate Floor

The Senate Foreign Relations Committee April 13 sent U.S. tax accords with Malta and New Zealand to the full Senate for…

U.S., Belgian Authorities Sign Agreement on Corresponding Pensions for Tax Purposes

The Treasury Department and Internal Revenue Service announced April 9 that U.S. and Belgium authorities have reached an agreement recognizing correspondences between…

IRS Chief Counsel Advice Addresses Interest Expense Allocable to Foreign Firm’s U.S. Insurance Business

The Internal Revenue Service Office of Chief Counsel, in a chief counsel advice memorandum released April 2, said a foreign taxpayer conducting a U.S. life insurance business must use the allocation method set forth in Treasury Regulations Section 1.882-5 to determine interest expense allocable to its U.S. branch for purposes of computing its U.S. income tax liability for 2001 and 2002 tax years.

U.S., Switzerland Announce Treaty Protocol to Allow Transferring of UBS Names to IRS

GENEVA – The United States and Switzerland signed a protocol March 31 allowing for the provisional application of their Aug. 19 agreement requiring Swiss banking giant UBS to hand over details on 4,450 secret bank accounts held by U.S. taxpayers.

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