United States Tax News
Final and proposed regulations issued on taxation of earnings of CFCs
16 October 2005
On 30 September 2005 Sweden and the United States signed a protocol to the Sweden-United states income tax treaty of 1 September 1994. Further details of the protocol will be reported subsequently.
16 October 2005
US and Mexico reach mutual agreement on eligibility of fiscally transparent entities to claim treaty benefits
16 October 2005
The Internal Revenue Service (IRS) has released the text of a private letter ruling (PLR) on 3 June 2005 holding that stock of a US corporation owned by a UK company through foreign entities that elect to be treated as disregarded entities under the US check-the-box regulations can qualify for the zero dividend withholding rate under
3 August 2005
The Netherlands State Secretary for Finance published Decree IFZ2005/546M on 6 July 2006 concerning the application of the 1992 income tax treaty between The Netherlands-United States to hybrid entities.
3 August 2005
The protocol of 8 March 2004 to the 1992 income tax treaty between the United States and the Netherlands entered into force on 28 December 2004. The protocol will generally be effective for taxable periods beginning on or after 1 January 2005, and the provisions of the protocol relating to withholding taxes will be effective for amounts paid or credited on or after 1 February 2005. Persons that were entitled to greater benefits under the US-Netherlands treaty before it was modified by the protocol of 8 March 2004 may elect for the application of the old provisions for a period of 12 months from the date on which the protocol provisions became effective.
19 January 2005
The US Treasury Department has announced that the protocol to the 1984 income tax treaty between the United States and Barbados, signed on 14 July 2004, entered into force on 20 December 2004. According to the Treasury Department announcement, the protocol will generally effective for taxable years beginning on or after 1 January 2005, and the provisions of the protocol relating to withholding taxes applies for amounts paid or credited on or after 1 February 2005.
19 January 2005
The protocol has been ratified by both states but has not yet entered into force. However, it is expected that the exchange of ratification instruments will take place timely as a result of which the protocol will be effective as from 1 January 2005.
7 September 2004