German Federal Fiscal Court Ruling Potentially Provides Reduced Withholding Rates to Certain US Entities
In a decision dated June 26, 2013 (Doc No I R 48/12, original available here), the German Federal Fiscal Court […]
Tax Conventions and Treaties
Cross-border exchange of information procedures
In this issue of Vox Tax, we analyze the recent wave of information sharing among national tax authorities. As tax […]
Opportunity to Claim Withholding Tax Overpayment on Dividends Received by Non-EU Investment Funds from Europe
In its verdict in Case C-190/12 (Emerging Markets Series of DFA Investment Trust Company), the European Court of Justice (ECJ) […]
Automatic Information Exchange: Did the Dog Just Catch the Bus?
John Harrington recently published an article in Tax Notes Today (available through the Lexis paywall) regarding eight potential challenges presented by […]
Can the IRS Circumvent U.S. Law by Issuing a Treaty Request?
Shortcuts to identifying the “soft spots” of a tax return have long tempted the IRS. Those shortcuts are generally quite […]
New Foreign Tax Credit Regulations Issued
On February 14, 2012, the US Treasury Department (“IRS”) published in the Federal Register regulations dealing with two separate but […]