United States Tax Treaty Policy Toward Developing Countries: The China Example One of the most significant developments in the US tax treaty program in the past decade has been the successful conclusion and ratification of treaties with an increasing number of developing countries. However, troublesome...
The article provides information about the income tax treaty and protocol signed by Belgium and the U.S. It is expected to improve the trade flows between the two countries because it would replace the 1970 tax accord. It discards the source-country withholding tax on direct investment dividends...
The article focuses on the Double Taxation Treaty (DTT) signed between the U.S. and Chile on February 4, 2010, which is set to undergo ratification procedures in both countries. The withholding tax rates regarding interest payments on loans granted by banks, insurance companies, and other insti...
Tax Treaty If a foreign corporation is a resident of a treaty country, i.e. a country which has a tax treaty with the US, then it is only taxed on ECI that is attributable to a permanent establishment (PE). What constitutes a PE is usually defined in the tax treaty. Frequent visits...
A tax pact with Chile passed a key test surviving a Senate panel vote, after a foreign tax credit language dispute slowed progress. The treaty dates back to 2010, but it’s been stuck in Senate purgatory awaiting a floor vote, even though it’s received a vote in the committee as...
The Tax Court’s interpretation of the business profits article as consistent with section 882(c)(2) may appear strained. This is understandable, given the Tax Court’s obligation (where possible) to harmonise the treaty with the statute. A different result could potentially o...
There’s progress on the US-Chile tax treaty, after lawmakers worked out concerns over language on foreign tax credits, which has slowed momentum toward ratification. A US-Chile tax pact dates back to 2010, but it’s still not gotten a Senate floor vote despite an OK from the Senate Forei...
Tax Treaty – US Trade with China The United States has signed a Double Tax Treaty with China. This can reduce tax burdens under certain circumstances in both trade and any China legal establishment. Please seek professional advice for specific China investment requirements. Treaty details can be ...
Estate Tax Relief and Planning under the U.S.-Canada Income Tax Treaty. The article discusses estate tax relief and planning under the U.S. and Canada Income Tax Treaty. The treaty addresses estate tax inequities that arise bet... Mathisen,Kristi,M.,... - 《Tax Adviser》 被引量: 0发...
Maikel was previously the coordinator of the BEPS project working to set up the Inclusive Framework on BEPS at the OECD’s Centre for Tax Policy Administration. He led the Multilateral Instrument project, contributed to the development of the Unified Approach (Pillar One), the treaty and EU aspe...