Americas

US court determines IRS properly denied discretionary tax treaty benefits

Amanda Varma and Brigid Kelly of Steptoe & Johnson, Washington, discuss the implications of the US district court’s decision Starr International Co. Inc. v. US, issued August 14, where the court concluded that the US competent authority acted reasonably when it denied a taxpayer’s request for discretionary tax treaty benefits under the US-Switzerland tax treaty. . . 

Asia-Pacific

China to offer key tax breaks to promote foreign investment

Richard Tan, a partner at Zhong Lun Law Firm, discusses the State Council’s new plan to promote foreign investment into China, presented August 16, which includes withholding tax deferral for reinvested dividends, an extension of the technological service enterprises tax incentive, and a new tax break for overseas income remitted back to China . . . 

Asia-Pacific

Hong Kong’s plan to legislate BEPS: what to expect

Stefano Mariani and Calvin Ng of Deacons discuss the Hong  Kong government’s July 31 announcements on its planned response to BEPS, which according to the authors, reveal that the territory will soon abandon its its longstanding stance as an easy and light-touch structuring jurisdiction . . . 

Americas

Argentina, Brazil agree on key tax treaty changes

Francisco Lisboa Moreira of Castro Barros, São Paulo, and Sandra Diaz of BaseFirma, Buenos Aires, discuss key changes to the Brazil-Argentina tax treaty, agreed to July 21, noting that taxpayers from both countries may need to evaluate this new arrangement . . .