Searching Content indexed under Tax Treaties by Mayer Brown ordered by Published Date Descending.
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IRS Issues Proposed Regulations Regarding Withholding Under Section 1446(f)
On May 7, 2019, the US Treasury Department and the Internal Revenue Service (the "IRS") released proposed regulations regarding Section 1446(f)
United States
15 Jul 2019
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
Proposed Regulations Change Calculus Of Section 956's "Deemed Dividend" For US Corporate Shareholders
On October 31, 2018, the US Internal Revenue Service ("IRS") released proposed regulations ("Proposed Regulations") that, if finalized, may substantially impact the way in which multinational corporations finance their operations.
United States
8 Nov 2018
A New Jersey Jughandle—New Legislation Brings Combined Reporting, A 95% DRD And Market-Based Sourcing To The Garden State
Two weeks ago, we provided a Legal Update on the then-current version of the New Jersey budget legislation.
United States
11 Jul 2018
IRS Issues Corrections To FATCA Regulations
On September 9, 2013, the Internal Revenue Service issued corrections to the final regulations implementing the Foreign Account Tax Compliance Act, issued in January 2013.
United States
9 Oct 2013
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
Foreign Account Tax Compliance Act of 2009
On March 18, 2010, President Obama signed into law the HIRE Act, economic stimulus legislation intended, among other things, to spur new job creation in the US economy.
United States
22 Apr 2010
US Ninth Circuit Reverses Course in "Xilinx", Rejects IRS Effort to Require Cost Sharing of Employee Stock Options
On March 22, 2010, a panel of the US Court of Appeals for the Ninth Circuit reversed its position on an issue of intense interest to multinational corporations that engage in research and development under cost sharing arrangements with their foreign affiliates.
United States
25 Mar 2010
President Obama´s International Tax Reform Proposals Regarding Offshore Accounts
On May 4, 2009, President Obama and Treasury Secretary Geithner unveiled two components of the Administration’s plan relating to US international tax reform.
United States
11 May 2009
US Department Of Commerce Breaks With Over 20 Years Of "Trade Remedy" Precedent
The US Department of Commerce (Commerce) has broken with precedent and chosen to apply countervailing duties to imports from a non-market economy (NME) nation. On October 18, 2007, Commerce announced its affirmative final determinations in the antidumping and countervailing duty (i.e., anti-subsidy) investigations of coated free sheet paper imports from Indonesia, Korea, and the People’s Republic of China (PRC).
United States
12 Nov 2007
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
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