A Private Letter Ruling, particularly important to utility companies that receive payments to facilitate the relocation of transmission equipment, was recently issued.

On December 28, 2007, representatives of the United States and Finland exchanged instruments ratifying and entering into force a new protocol (the “Protocol”) amending the 1989 bilateral income tax treaty between the two countries (the “Treaty”).

Taxpayers planning to claim Section 1603 cash grants in lieu of the Section 45 production credit or Section 48 investment credit for certain alternative energy property must file an application no later than Sept. 30, 2012, whether or not the property has been placed in service.

Almost two years ago, the Organisation for Economic Co-operation and Development launched a radical and far-reaching review of the international tax system.

On February 27, 2013, the Tax Treaty signed between Mexico and Latvia and its Protocol were published in the Mexican Official Gazette.

On April 25, 2023, the IRS's Advance Pricing and Mutual Agreement ("APMA") Program issued new interim guidance for its review of taxpayer Advance Pricing Agreement ("APA") requests.

On May 7, 2019, the US Treasury Department and the Internal Revenue Service (the "IRS") released proposed regulations regarding Section 1446(f)

The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation...

On April 21, 2020, the Internal Revenue Service (the "IRS") published a helpful revenue procedure (Rev. Proc. 2020-20), (the "Procedure") that, in general, excludes days present in the ...

Entrepreneurs and professionals with global interests face a unique challenge: the US tax system reaches far beyond its borders. US citizens...

The OECD Base Erosion and Profit Shifting (BEPS) Project became a prominent feature of the international tax landscape following the publication of the first report in February 2013.

There has been considerable discussion about the effect that the travel restrictions resulting from the COVID-19 pandemic might have on the tax residence of companies

In this article, the authors examine the necessity of including a multilateral instrument in the inclusive framework workplan...

As a general matter, all U.S. citizens and U.S. residents are treated as U.S. tax residents. A non-U.S. citizen is generally classified as a nonresident for U.S. tax purposes unless they satisfy one of two tests: the green card test or ...

his article will explore two cases where arbitration under a B.I.T. provided ephemeral benefits.

On June 21, the Treasury published proposed and final regulations under Code §951A. They address, inter alia, an expansion of the high-tax kickout exception applicable to Subpart F Income.

With all due respect for persons who are involved in, interested in, or just cognizant of the U.S. tax treaty program — which is one way of referring to the efforts of the Treasury...

On 23 November 2022, the Dutch Ministry of Finance issued a new Decree outlining its position on the application of tax treaties and domestic withholding taxes in light of hybrid situations...

On 22 March 2022, the Organisation for Economic Co-operation and Development ("OECD") published a public consultation document proposing new and amended reporting requirements with respect to...

Now, in a competent authority arrangement ("CAA") between the US and Malta, this interpretation has effectively been shut down.