Treaties

Topics

June 1, 2010

U.S.-Switzerland Protocol Will Allow Handover of UBS Account Holder Information

The United States and Switzerland announced a new protocol to allow the Swiss government to provide information to the IRS on U.S. account holders of Swiss bank UBS.

May 1, 2010

IRS Provides Guidance on Deemed Dispositions by Canadian Emigrants

The IRS has issued guidance for individuals who emigrate from Canada and wish to make an election under the U.S.-Canada income tax treaty regarding Canadian departure tax (Rev. Proc. 2010-19).

May 1, 2009

Tax Treaty Net Basis Elections

Tax treaties may offer special elections that recharacterize certain types of FDAP income that would otherwise be subject to withholding tax as effectively connected and thus taxable on a net basis at U.S. graduated rates.

November 1, 2008

Selected Provisions of the Fifth Protocol to the U.S.-Canada Income Tax Treaty

In 2007, the United States and Canada signed the Fifth Protocol to the 1980 U.S.-Canada Income Tax Treaty. The changes to the treaty resulting from this new protocol are numerous and are quite significant for cross-border business

August 1, 2008

Treatment of Loans to U.S. Partners Under the U.S.-Germany Tax Treaty

Germany’s federal tax court ruled that interest payments received by a U.S.-resident partner on a loan to his German partnership can be taxed only in the United States in accordance with Article 11(1) of the U.S.-Germany income tax treaty and are exempt from German taxation.

March 1, 2008

Commentary on the Canada-U.S. Tax Treaty’s Fifth Protocol

The U.S. Secretary of the Treasury and the Canadian Minister of Finance signed an important tax agreement (the Fifth Protocol) updating certain provisions of the Canada-U.S. Tax Treaty.