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International Tax Issues U.S. Treasury Tax Treaty

Mayer Brown

Congress Proposes a ‘Big Stick’ to Target Discriminatory Tax Measures

Mayer Brown on

At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”)....more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Eversheds Sutherland (US) LLP

US Treasury issues notice to Hungary to formally withdraw from longstanding US-Hungary Income Tax Treaty

The US Treasury is moving to formally withdraw from the US-Hungary income tax treaty, which has been in effect since 1979 (the Treaty). For previous reporting by Eversheds Sutherland regarding the Treaty, see US-Hungary tax...more

Holland & Knight LLP

U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status

Holland & Knight LLP on

The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty). It provides for purposes of...more

Alston & Bird

International Tax Advisory: America’s Next Tax Model

Alston & Bird on

The Treasury recently released a revised U.S. Model Income Tax Convention (the “2016 Model”), the U.S. starting point for bilateral treaty negotiation, last updated a decade ago. In May 2015, the Treasury circulated several...more

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