New U.S.-Netherlands Accord Eliminates Qualification Certification to Claim Tax Treaty Benefits

Competent authorities for the United States and the Netherlands have amended a 2007 mutual agreement procedure (MAP) to eliminate the “qualification” procedure used for claiming benefits under the U.S.-Netherlands tax treaty, according to an agreement released March 30 by the Internal Revenue Service.

IRS Stressing Focus on Global Examinations, Seeking More Data on Taxpayers, KPMG Says

The Internal Revenue Service is intensifying its approach on audits of international issues, seeking increased information from taxpayers, and amping up not just…

Ninth Circuit Reissues ‘Xilinx’ Opinion, Affirms Tax Court Ruling on Stock Options

The U.S. Court of Appeals for the Ninth Circuit March 22 reissued its opinion in the Xilinx case on stock options to find for the taxpayer, reversing the stance taken in…

House Ways and Means Panel OKs Small Business Tax Bill; Treasury Concerned over Language Impacting Tax Treaties

The House Ways and Means Committee March 17 approved a $17 billion small business tax bill (H.R. 4849) but changes might be forthcoming after…

Proposals on Tax Havens, Job Creation Expected to Clear House Ways and Means Committee Today

The Ways and Means Committee is expected to approve legislation (H.R. 4849) March 17 that would extend the Build America Bonds program, but that support will…

U.S.-U.K. Treaty Does Not Exempt U.K. Foundation from U.S.-Source Dividends Tax

The Internal Revenue Service Office of Chief Counsel, in a chief counsel advice memorandum released March 12, said the U.S.-U.K. income tax treaty does not exempt a U.K.-based private foundation from…

IRS Offers Guidance to Emigrating Canadians Who Elect to Pay U.S. Income Tax on Gains

The Internal Revenue Service March 8 offered guidance in Revenue Procedure 2010-19 for individuals who emigrate from Canada and want to make an election for…

Payments of U.S.-Source Income to Foreign Persons Skyrocketed Between 2005, 2007

Payments of U.S.-source income to foreign persons skyrocketed more than 70 percent between 2005 and 2007, with the vast majority of the payments going…

U.S. Official Rules out Renegotiation of Accord with Switzerland on UBS Data

The United States is unwilling to renegotiate an agreement with Switzerland under which the Swiss government promised to…

U.S. Signs New Tax Treaties with Chile, Hungary

Treasury Secretary Timothy Geithner and Chilean Finance Minister Andres Velasco Feb. 4 signed the first U.S. income tax…

« Previous Page — Next Page »