Reports on an Internal Revenue Service (IRS) ruling that clarifies a 1990 tax treaty between the US and India, detailing the tax benefits visitors on student visas would receive in the US. Unusual provision of the treaty; How the IRS interprets the treaty; More.Jaschik...
Tax Treaty Benefits US Court Determines IRS Properly Denied Discretionary Tax Treaty BenefitsUS Court Determines IRS Properly Denied Discretionary Tax Treaty BenefitsAmanda Pedvin Varma
Appeals comes with other potential pitfalls. Historically, taxpayers with cross-border tax issues eligible for treaty relief could take a case to Appeals and, to the extent Appeals did not eliminate the IRS-initiated adjustment, could then pursue bilateral relief via the mutual agreement p...
In response to international concerns regarding hybrid arrangements used to achieve double non-taxation, Action 2 of the OECD's Base Erosion and Profit Shifting (“BEPS”) project, and two final reports address hybrid and branch mismatch arrangements.[1]The Hybrid Mismatch ...
Panelists will discuss how to apply tax treaties to returns and how to get treaty benefits in foreign countries. The U.S. has treaties with more than 60 countries that could reduce tax and eliminate double tax for your clients involved in overseas employment and transactions. ...
US Tax Scene: IRS Issues Advice on Treaty Benefits for Dual-Incorporated CompanyMorrison, PhilO’Donnell, JeffWilson, RandyHardin, JamesIntertax
US Tax Scene: IRS Issues New Procedures for Treaty-Based Excise Tax ExemptionsSafranek, RCruz, JIntertax International Tax Review
Tax TreatyTax Treaties§894§1.894-1This letter responds to the request in Notice 2017-28 for public comment on recommendations for items that should be included on the 2017-2018 Priority GuidanceKadet, Jeffery MSocial Science Electronic Publishing...