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International Tax Alerts

8/24/2010	President Signs H.R. 1586 Containing International Tax Provisions 121 KB PDF File
6/8/2010	Financial Bank Account Reporting Guidance Revised; Limited Relief Extended 563 KB PDF File
5/13/2010	New Law Expands Limitations Period With Respect to the Failure to Report Certain Foreign Activities 101 KB PDF File
4/19/2010	French Supreme Court Issues Ruling on Commissionaire Structures and the Creation of French Permanent Establishments 1361 KB PDF File
4/8/2010	Chinese Tax Authority Targets Foreign Businesses in China 108 KB PDF File
4/8/2010	Chinese Tax Authorities Now Require Transfer Pricing Documentation 103 KB PDF File
4/8/2010	U.S. Tax Court Decision on Xilinx 104 KB PDF File
3/1/2010	United States and Chile Sign a New Income Tax Treaty 106 KB PDF File
3/1/2010	United States and Hungary Sign a New Income Tax Treaty 108 KB PDF File
2/19/2010	Obama Administration Outlines New Proposals to Reform 113 KB PDF File
2/10/2010	New Protocol to United States – France Income Tax Treaty Enters into Force Creating Possible Refund Opportunity for Certain Dividend and Royalty Payments 103 KB PDF File
2/10/2010	United States-Italy Income Tax Treaty Enters into Force 108 KB PDF File
1/14/2010	Tax Court Rules Against IRS in VERITAS Software Corp. Cost-Sharing Trial 104 KB PDF File
1/14/2010	Tax Court of Canada Rules in Favor of GE Capital Canada in Guarantee Fee Trial 98 KB PDF File
12/16/2009	Mexican Tax Reform of 2010 162 KB PDF File
11/3/2009	New Protocol Amending United States - Switzerland Income Tax Treaty Signed on September 23, 2009 155 KB File
9/23/2009	IRS Extends Deadline for Foreign Bank Account Reporting Under Voluntary Disclosure Program 150 KB PDF File
8/19/2009	Internal Revenue Service Issues Additional Guidance on Foreign Bank and Financial Accounts 157 KB PDF File
7/14/2009	Temporary Relaxation of German NOL Limitation and Interest Barrier Rules 185 KB PDF File
6/18/2009	United States and Hungary Agree on New Income Tax Treaty 174 KB PDF File
6/4/2009	Internal Revenue Service Expands Obligation to Report Foreign Bank and Financial Accounts; Issues Guidance on Voluntary Disclosure 161 KB PDF File
5/13/2009	Obama Administration Outlines Proposals to Reform International Tax Provisions and to Strengthen Enforcement of Offshore Tax Disclosures 179 KB PDF File
4/9/2009	Stricter Reporting Requirements for U.S. Transferors of Property to Foreign Corporations 179 KB PDF File
4/9/2009	New Filing Requirements for Computing Disqualified Interest Expense Under Section 163(j) 155 KB PDF File
4/6/2009	Transfer Pricing News - April 2009 357 KB PDF File
2/11/2009	Significant Changes to United States – France Income Tax Treaty under New Protocol 163 KB PDF File
2/11/2009	Relaxation of Rules Relating to Certain Loans from Controlled Foreign Corporations to United States Taxpayers 149 KB PDF File
2/5/2009	The Temporary Cost-Sharing Regulations 217 KB PDF File
1/19/2009	Conduit Financing Proposed Regulations Affect Certain Disregarded Entities 28 KB PDF
1/19/2009	Vodafone Case: Holding Companies with Investments in India Affected 28 KB PDF
1/19/2009	Final Regulations on the Application of Subpart F to Certain Contract Manufacturing Arrangements 28 KB PDF
1/8/2009	IRS Issues Final and Temporary Cost-Sharing Regulations 25 KB
12/18/2008	Fifth Protocol Amending the United States-Canada Income Tax Treaty is in Effect 29 KB PDF File
12/11/2008	United Kingdom (“UK”) Taxation of European Union (“EU”) Sourced Dividends Ruled Unlawful by High Court in London 30KB PDF File
12/3/2008	The United Kingdom Pre-Budget Report (the “Report”) Announces an Exemption Regime for the Taxation of Foreign Profits to be Introduced in the 2009 Finance Act 49KB PDF File
11/21/2008	United States Tax Authorities Consider Changes to USRPI Determination 34KB PDF File
11/18/2008	Internal Revenue Service Announces Automatic Penalty Assessment for Late Filing of Form 5471 33KB PDF File
11/18/2008	Brazil Exempts Foreign Fixed Income Investments and Loans from IOF Tax 30KB PDF File
10/8/2008	Ratified U.S.-Canada Protocol Provides for Refund Opportunity on Interest Withholding Tax 38KB PDF File
10/8/2008	IRS Allows Certain Loans from CFC’s Without Deemed Income Inclusions 32KB PDF File
8/25/2008	New Internal Revenue Manual provision mandates stricter scrutiny and regulation of payments to foreign persons 40KB PDF File
8/7/2008	Mexican Authorities Repeal Recent Administrative Rule Including Transfers and Transactions from Foreign Banks Under the Cash Deposits Tax 30KB PDF File
8/7/2008	New German Change-in-Ownership Rules Severely Restrict NOL Carryovers 32KB PDF File
8/6/2008	UK Company’s Interest Owed to Foreign Parent: Deduction Based on Accrual Method 40KB PDF File
8/1/2008	Delay in Application of Worldwide Allocation of Interest 28KB PDF File
7/16/2008	Technical Explanation of the Fifth Protocol to US-Canada Income Tax Treaty Released July 10, 2008 36KB PDF File
7/8/2008	New Tax on Cash Bank Deposits Effective in Mexico 25KB PDF File
7/8/2008	Delaware Included as Tax Haven under New Brazilian Tax Law 25KB PDF File
7/7/2008	IRS Rules that Partners, not the Partnership, Must File Form 926 for Transfers of Property to a Foreign Corporation 30KB PDF File
7/2/2008	International Tax Alert - Italian Government Decree Would Eliminate Favorable Rules on the Taxation of Stock Options 37KB PDF File
6/30/2008	IRS Substantially Expands Jurisdiction of the APA Program 26KB PDF File
6/13/2008	Brazil Supreme Court Maintains Limited Judicial Exemptions on Social Contributions Tax 26KB PDF File
5/22/2008	IRS Simplifies Late Filing Relief Procedures for Certain FIRPTA Transactions 36KB PDF File
5/13/2008	Foreign Bank and Financial Account Filing Requirements 74KB PDF file
4/14/2008	Ireland Changes in Taxation of Foreign Dividends 27KB PDF file
4/9/2008	U.S. Tax Filings for Foreign Companies 39KB PDF file
4/2/2008	U.S. Alert: Interest Paid by a German Partnership to a U.S. Partner is Exempt from German Tax under the U.S.-German Treaty 29KB PDF File
3/17/2008	UK Disregard Regulations: New Election, if Required, Should be Made by March 31, 2008 25KB PDF file
3/6/2008	New Switzerland Witholding Tax Rules Relating to Repatriation and Reorganizations 29KB PDF file
3/6/2008	New Proposed Regulations on Contract Manufacturing 39KB PDF File
3/5/2008	India Union Budget 2008 686KB PDF File
2/25/2008	Third Circuit Court of Appeals Decision Upholds Regulation That May Deny Deductions on Late Filed Returns of Foreign Corporations Conducting Business in the U.S. 29KB PDF File
2/12/2008	Refund Opportunity Under New U.S.-German Protocol 36KB PDF File
2/6/2008	Irish Government Publishes Several Changes in Finance Bill for 2008 26KB PDF File
1/16/2008	IRS Issues Regulations on Overall Domestic and Foreign Losses 28KB PDF file
1/16/2008	Impact of New Treaty Protocol (Fifth Protocol) with Canada on Non-deductible Payments 29KB PDF file
12/19/2007	Mexican Single Rate Business Tax (IETU) and U.S. Foreign Tax Credit 24KB PDF File
11/26/2007	IRS Directive Makes Audits of IRC §965 Repatriation Mandatory 38KB PDF File
11/20/2007	Canadian Withholding on Arm’s Length Interest 26KB PDF File
10/2/2007	United States and Canada Sign Fifth Protocol to U.S.-Canada Income Tax Convention 39KB PDF File
9/5/2007	2008 German Tax Reforms: Loss Carry-forward Limitation Rules 30KB PDF File
8/22/2007	Draft Form 1118 Issued by Internal Revenue Service 30KB PDF File
8/7/2007	Tax Rate Changes in the UK, Germany and China 29KB PDF File
7/30/2007	UK Issues Management Expenses Anti-Avoidance Guidance 27KB PDF File
7/27/2007	German Government Proposes Significant Expansion of Anti-Abuse Rules 27KB PDF File
7/26/2007	French Tax Authorities Issue Guidelines Regarding Rules for Group Tax Regime 27KB PDF File
7/26/2007	Finalization of Temporary Regulations Clarifying Information Reporting by Foreign and Foreign-owned Domestic Corporations 28KB PDF File
4/24/2007	UK Taxation of Foreign Profits 60KB PDF File
4/24/2007	British Columbia ULC 27KB PDF File
4/16/2007	German Government Approves Draft Tax Reform 2008 39KB PDF File
4/3/2007	Proposed FTC Regulations 33KB PDF File
3/26/2007	Canada Proposes Major Changes to International Tax Rules 43 KB PDF File
3/22/2007	Final Regulations Issued Under Dual Consolidated Loss Provisions 39 KB PDF File
2/26/2007	Form 1042 Update 37 KB PDF File
2/23/2007	Qualified Patent Cross Licensing Arrangements 30 KB PDF File
2/15/2007	IRS Comments on its Developing Position on Requesting Taxpayer FIN 48 Workpapers 30 KB PDF File
2/13/2007	Gain Recognition Agreements 30 KB PDF File
2/12/2007	Manufacturing Exception to Subpart F Income 31 KB PDF File
2/5/2007	Notice 2007-13 30 KB PDF File
1/23/2007	IRS Notice 2007-9 29 KB PDF File
12/14/2006	Germany: 2007 Annual Tax Bill Tightens Treaty Shopping Rules 25 KB PDF File
12/14/2006	German Tax Reform Proposal to Reduce Corporate Tax Rates 26 KB PDF File
11/3/2006	Imperial Oil Case Ruling Regarding Canadian Foreign Exchange Losses 30 KB PDF File
11/3/2006	US, UK Enter Competent Authority Agreement to Prevent Double Taxation 25.5 KB PDF File
10/23/2006	Proposed Dutch Corporate and Individual Tax Cuts 27KB PDF File
9/21/2006	Sales and Use Tax in Puerto Rico 27KB PDF File
9/20/2006	UK CFC Rules – ECJ Decision in the Cadbury Schweppes Case 32KB PDF File
8/29/2006	New Temporary U.S. Transfer Pricing Services and Intangibles Regulations 57KB PDF File
8/11/2006	"Technical Taxpayer Rule" for Foreign Tax Credits 34KB PDF File
7/10/2006	Private Equity Funds-Tax Efficiencies 34KB PDF File
7/5/2006	IRS Issues Additional Guidance on Section 7874 ("Inversions") 44KB PDF File
6/27/2006	Treasury Issues Regulations Addressing Related Party Reporting Requirements for Foreign Subsidiaries and Foreign Owned U.S. Corporations 29KB PDF File
6/14/2006	Deadline for Filing Form TDF 90-22.1: Report of Foreign Bank and Financial Accounts 29KB PDF File
6/6/2006	New Protocol to US-German Income Tax Treaty 25KB PDF File
5/19/2006	Temporary Exception from Subpart F for Certain Dividends, Interest, Rents and Royalties 25KB PDF File
5/19/2006	Earnings Stripping Regime Adopts Look-Through Rule for Partnership Items 25KB PDF File
5/19/2006	Two-Year Extension of Active Financing Exception to Subpart F 25KB PDF File
4/27/2006	Lower corporate tax and withholding tax rates proposed in the Netherlands 30KB PDF File
3/23/2006	Voluntary Compliance Program for Payments to Foreign Persons Set to Expire March 31 31KB PDF File
3/20/2006	International R&D Credits and Incentives Update 29KB PDF File
3/17/2006	IRS Relaxes Treaty-Based Return Disclosure Requirements 39KB PDF File
3/14/2006	India Union Budget 2006 370KB PDF File
3/13/2006	Recent Spain-U.S. Competent Authority Agreement May Present a Refund Opportunity 31KB PDF File
2/21/2006	Recent Changes in Italy’s Tax Laws Allow for Step Up in Basis for Certain Assets and a Limited Capital Gains Exemption 31KB PDF File
2/14/2006	Possible Refund of Dividend Withholding Tax in Norway 75KB PDF File
2/9/2006	Notice 2006-16 127KB PDF File
1/31/2006	French Finance Bills 98KB PDF File
11/18/2005	UK VAT Refund Opportunity 99KB PDF File
10/14/2005	German Federal Tax Court Expands Availability of Treaty Benefits 120KB PDF File
10/10/2005	IRS Provides Guidance on Retroactive Section 367(a) Gain Recognition Agreement 36KB PDF File
10/3/2005	Canada Withdraws Corporate Tax Reduction 93KB PDF File
8/30/2005	Section 965 Guidance 49KB PDF File
6/1/2005	Tax Arbitrage: Hybrid Entities 110KB PDF File
5/19/2005	Notice 2005-38: New Guidance on Repatriation 120KB PDF File
5/12/2005	Deadline for Filing Form TDF 90-22.1: Report of Foreign Bank and Financial Accounts 39KB PDF File
5/12/2005	E.U. Customs Duty Refund Opportunity 38KB PDF File
4/11/2005	An Overview of Transfer Pricing in Latin America 87KB PDF File
3/23/2005	Proposed UK Anti-Avoidance Legislation Poses Major Challenge to U.S. International Tax Planners 52KB PDF File
2/22/2005	Tax Saving Alternative for U.S. Exporters 52KB PDF File
1/12/2005	Switzerland Reduces Withholding Tax 33KB PDF File
12/1/2004	New Filing Requirement for Foreign Disregarded Entities 128KB PDF File
11/1/2004	Repatriation 152KB PDF File
10/19/2004	Production Activities Deduction Replaces Extraterritorial Income Exclusion 146KB PDF File
10/18/2004	European Limited Liability Company Regulations - "Societas Europaea" (SE) 161KB PDF File
10/18/2004	Mexico: Proposed Tax Bill For 2005 158KB PDF File
7/14/2004	U.S. & Mexico Sign Social Security Agreement 33KB PDF File
6/21/2004	Deadline for Filing Form TDF 90-22.1; Report of Foreign Bank and Financial Accounts 36KB PDF File
6/10/2004	Form 8802 U.S. Residency Certification Update 33KB PDF File
6/4/2004	Brazilian Tax Savings Opportunity - New COFINS & PIS Taxes 42KB PDF File
3/31/2004	New U.S.-Japan Income Tax Treaty 51KB PDF File
3/4/2004	New Opportunity Created By German Thin Capitalization Rules 42KB PDF File
3/3/2004	Insolvent CFC's Can Trigger Ordinary Worthless Stock Deduction 35KB PDF File
1/28/2004	New Procedures for IRS Certification of United States Residency 34KB PDF File
1/14/2004	New Form 8858 Required for U.S. Taxpayers Owning Foreign Disregarded Entities 34KB PDF File
1/14/2004	New German Tax Law Changes To Severely Impact Businesses 909KB PDF File
12/16/2003	Changes in the Federal and State Estate, Gift and Generation-Skipping Transfer Tax Laws 35KB PDF File
11/12/2003	Proposed Thin Cap Rules for Dutch Companies 43KB PDF File
11/12/2003	Split Dollar Life Insurance Policies 35KB PDF File
11/12/2003	German Transfer Pricing 41KB PDF File
11/7/2003	2004 Retirement Plan Cost of Living Adjustments 545KB PDF File
11/7/2003	U.S.-U.K. Double Taxation Agreement & Expatriate Participation in a Foreign Plan 535KB PDF File
10/21/2003	New York State Anti-PIC Legislation 1MB PDF File
10/3/2003	Transfer Pricing 939KB PDF File