Sunday May 19, 2013
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US Tax Treaty Developments

The US tax treaty developments newsalert series covers developments related to the interpretation and application of US income tax treaties, including international developments that may impact US tax treaty interpretation or policy.

February 2013

  • New US-Poland treaty incorporates modern limitation on benefits article
  • US and Norwegian tax authorities address treaty eligibility for fiscally transparent entities

January 2013

  • US-Japan protocol exempts interest from source State taxation and reduces ownership for exemption from tax on certain dividends to 50%
  • New protocol to US-Spain treaty signals possible changes in US policy on limitation on benefits

July 2012

  • US and Canada Competent Authority Agreement sets standards on attribution of profits to a PE

June 2012

  • Agreement reached on revisions to US income tax treaties with Japan and Spain; additional update on other US income tax treaties
  • US-Netherlands competent authority agreement allows treaty benefits for Dutch residents receiving US source dividends and interest through an LFMA

May 2012

  • Chilean Treaty sent to US Senate for ratification
  • US-German Competent Authority Agreement addresses characterization of foreign pension fund

January 2012

  • US tax treaty update
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Contacts
Tim Anson
International tax services co-leader
Tel: +1 (202) 414 1664
Michael Urse
International tax services co-leader
Tel: +1 (216) 875 3358
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