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OECD Inclusive Framework Reaches Consensus on Pillar Two “Side by Side” Package

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United States Tax News

OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments

2 September 2007
Final regulations issued for determination of earnings and profits attributable to stock of CFCs

2 September 2007
US

2 September 2007
German Lower Court

29 July 2007
US Senate hearings on new treaty and protocol between Belgium and US

29 July 2007
Belgian abolition of fixed FTC incompatible with tax treaty between Belgium and US

29 July 2007
Treasury Department reissues list of international boycott countries that result in restriction of US tax benefits

29 July 2007
US Senate hearings on protocol to treaty between Denmark and US

29 July 2007
US Senate hearings on protocol to treaty between Germany and US

29 July 2007
US Senate hearings on protocol to treaty between Finland and US

29 July 2007
Non-discrimination and group income elections

2 July 2007
Treasury Department released statement on attribution of profits under Authorized OECD Approach (AOA)

2 July 2007
US court orders IRS summons enforced under US-Mexico income tax treaty

2 July 2007
Treaty between Belgium and US ratified

18 June 2007
Italian tax authorities interpret application of Art. 15 of EU-Swiss Agreement

18 June 2007
Treaty between Australia and United States – US tax debts not enforceable in

18 June 2007
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007
Final regulations issued on US withholding exemption for portfolio interest received by foreign persons

28 May 2007
Revised Commentary on Article 7 of OECD Model released

28 May 2007
Tax treaty between Australia and United States – Australia's Federal Court rejects tax treaty override

28 May 2007
Proposed regulations issued to curb foreign tax credit abuses

28 May 2007
IRS issues fact sheet on reporting requirements for foreign financial accounts

28 April 2007
US

28 April 2007
Treaty between United States and Bulgaria signed

28 April 2007
Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007
Treaty between United States and Japan – US court dismisses claims for relief for information exchanged under treaty

24 March 2007
Indian ruling on classification of income of Canadian and US foreign institutional investors making portfolio investments in India

24 March 2007
Treasury Department reissues list of international boycott countries that result in restriction of US tax benefits

24 February 2007
China signs first APA with US

24 February 2007
Report on Attribution of Profits to PEs released

24 February 2007
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