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
You’re filing as aforeign corporation, which doesn’t have a permanent establishment in America under anincome tax treaty, and you file the proper paperwork (i.e.,Form 8833). The foreign corporation meets the requirements of Section 883 and has fully complied with the requirements of Sections...
The commission president was responding to a question about whether the EU should activate Article 122 of its treaty, which allows it to take “measures appropriate to the economic situation” if “severe difficulties arise in the supply of certain products”. The EU’s 27 heads of state and ...
LGT Bank in Liechtenstein decided to go "hi tech" so, in April 2001, they hired a charming young computer technician named Heinrich Kieber to digitize their hard copy records. Unfortunately for LGT, and all the clever tax cheats doing business with LGT, it turns out that Kieber was an inte...
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...
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