Americas

United Arab Emirates and Barbados sign tax treaty

September 27, 2014

The United Arab Emirates and Barbados, on Sept. 26, signed an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement emphasizes the desire of both countries to avoid double taxation on the income of individuals and companies, commercial sea and air transport, and on other similar taxes. Release

USCIB sees flaws in draft US model tax treaty

September 18, 2015

The United States Council for International Business has written to US Treasury, arguing that draft provisions in the US model tax treaty released last May "tilt too far in their attempt to prevent inappropriate claims of treaty benefits."  The group is concerned with provisions on special regimes, subsequent changes in law, and limitation on benefits. See: USCIB. Related: MNE Tax

IRS regs extend section 956 antiabuse rules to partnership transactions, address FPHCI exception for active rents and royalties

September 3, 2015

The US IRS on September 2 released temporary and proposed regulations on the application of the section 956 deemed dividend rules to partnership transactions. Regs were also issued providing that a controlled foreign corporation (CFC) must conduct relevant activities itself to take advantage of the foreign personal holding company income (FPHCI) active rent and royalties exception, including in situations where a cost sharing . . .

US and Curacao sign Model 1 FATCA IGA

January 12, 2015

The US Treasury Department has updated its FATCA website, reporting that Curacao has signed a Model 1 intergovernmental agreement (IGA) with the United States as of December 16, 2014. The text of the agreement is available. See, agreement.

Michael Lebovitz and Stephen Weerts join White & Case

January 6, 2015

Michael Lebovitz and Stephen Weerts have joined White & Case's Los Angeles office, the firm announced January 5. The lawyers, both formerly with DLA Piper, will work on legal and tax aspects of international joint ventures, cross-border mergers and acquisitions, and international corporate finance and capital markets transactions. See, White & Case release.

FATCA challenged in Canadian court and United Nations

August 13, 2014

Two Canadian-U.S. dual citizens, on August 11, filed suit in the Federal Court of Canada challenging the constitutionality of the intergovernmental agreement signed by the U.S. and Canada that implements FATCA.The lawsuit, funded by the Alliance for the Defense of Canadian Sovereignty (ADCS), alleges that the intergovernmental agreement violates provisions of the Canadian Charter of Rights and Freedoms . . .

US and Uzbekistan agree in substance on Model 1 FATCA IGA

July 7, 2014

Us Treasury Department has updated its FATCA website, reporting that Uzbekistan has reached an “agreement in substance” on a Model 1 intergovernmental agreement (IGA) with the United States and consented to this status as of June 30.

U.S. and Haiti agree in substance on FATCA IGA

July 1, 2014

U.S. Treasury Department has updated its FATCA website, reporting that Haiti has reached an “agreement in substance” on a Model 1 intergovernmental agreement (IGA) with the United States and consented to this status as of June
1 28 29 30 31
Simple Share Buttons