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Protocol to Canada treaty signed

Article Abstract:

The United States and Canada signed a fifth protocol to their income tax treaty on 21 September 2007. The protocol affects hybrid entities, withholding taxes on dividends and guarantee fees, permanent establishments, employee benefits, and competent authority cases.

Author: Fuller, Thomas, Cohen, Harrison, Slaats, Sandra
Publisher: Aspen Publishers, Inc.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
Canada

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US tax scene: final portfolio interest exemption regulations released

Article Abstract:

US Treasury regulations clarifying the portfolio interest rule were published in the Federal Register on 12 April 2007. Nonresident aliens and foreign corporations have to pay 30% withholding tax, while issues regarding the 10% shareholder test are clarified.

Author: Fuller, Thomas, Sina, Jeremy, Renfroe, Diane
Publisher: Aspen Publishers, Inc.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
Legal issues & crime, Government regulation (cont), Government regulation, Partnerships, Legal/Government Regulation, Taxation, Laws, regulations and rules, Partnership, United States. Department of the Treasury

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US Tax Scene: new US-Germany protocol zero rates intercompany dividends, updates limitation on benefits provision

Article Abstract:

Amendments in the 1989 Income Tax Convention and Protocol signed between United States (US) and the Germany are discussed. A new protocol with amendments is signed between US and the Germany on June 1, 2006.

Author: Fuller, Thomas, Sina, Jeremy
Publisher: Aspen Publishers, Inc.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2006
Germany

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Subjects list: United States, Interpretation and construction, Tax treaties, Tax policy
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