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Treasury Adds Color To Grecian Repeal – Proposed Regulations Implement New Section 864(C)(8) For Sale Of Partnership Interests By Foreign Partners
On December 20, 2018, the US Department of Treasury and the IRS released proposed regulations under Section 864(c)(8) of the Code on the treatment of a foreign partner's transfer of an interest in a partnership...
United States
14 Jan 2019
2
Treasury Releases Proposed Regulations On Foreign Tax Credits Under New International Tax Rules
On November 28, 2018, the US Department of Treasury and Internal Revenue Service released proposed regulations on the determination of foreign tax credits
United States
27 Dec 2018
3
Innovation Box Regime Proposed For US Tax Code
US Congressman Charles W. Boustany Jr. (R-La) and Congressman Richard Neal (D-Mass), both senior members of the Ways and Means Committee, released draft legislation that would create an "innovation box regime" in the US tax code.
United States
31 Jul 2015
4
The OECD’s Action Plan On Base Erosion And Profit Shifting
The Organisation for EconomicCoordination and Development released its highly anticipated Action Plan on Base Erosion and Profit Shifting, which was then unanimously approved by the G-20 Finance Ministers at their July 20, 2013 meeting in Moscow.
United States
1 Aug 2013
5
Alignment Of Sourcing And Tax Principles In Contract Manufacturing
Contract manufacturing offers a variety of benefits to non-US subsidiaries of US-based multinational companies that want to outsource the manufacture of their products to be sold in the United States.
United States
2 Jan 2013
6
Significant Revisions to US International Tax Rules
The Education Jobs and Medicaid Assistance Act of 2010 (Pub. L. No. 111-226) (the "Act") became law on August 10, 2010. While the Act’s primary purpose is to provide financial assistance to US states for education and Medicaid spending, several international tax provisions were included to offset the spending increases.
United States
 
1 Sep 2010
7
IRS Liberalizes The Rules For A Foreign Subsidiary To Make Short-Term Loans To Its US Parent To Ease Liquidity
The Internal Revenue Service (the "Service") recently issued guidance intended to address taxpayer difficulties in funding their operations as a consequence of current market developments.
United States
16 Oct 2008
8
New Protocol To US-Canada Tax Treaty Would Eliminate Withholding Tax On Interest Payments
On September 21, 2007, United States Treasury Secretary Henry Paulson and Canadian Finance Minister Jim Flaherty signed the much anticipated 5th protocol to the existing United States-Canada income tax treaty (the "Treaty").
United States
 
28 Sep 2007
9
Temporary And Proposed Regulations Under Section 883
On June 22, 2007, the US Treasury Department and the US Internal Revenue Service (the "IRS") released temporary and proposed regulations under section 883 (the "Temporary Regulations"), relating to the reciprocal shipping income exemption.
United States
24 Aug 2007
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