United Arab Emirates and Barbados sign tax treaty

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

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

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 . . .


FATCA challenged in Canadian court and United Nations

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 . . .


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

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 30.

Federal Government

G7 leaders agree to arbitration for double tax disputes, say OECD should monitor BEPS implementation

G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .

UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .