Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

Treaty Updates Page


Today we added a new web page that lists recent updates to U.S. income tax treaties.

The page includes links to the source for each item. For example:

  1. The State Department website has signed treaty documents for recent finalized U.S. income tax treaties;
  2. The Treasury Department website has Technical Explanations for certain income tax treaties;
  3. The Joint Committee on Taxation website has explanations of proposed treaties; and
  4. The Senate website includes the roll call vote for approving treaties.

The following countries have had some sort of movement with respect to U.S. income tax treaties in recent years:

  • Chile (new proposed treaty)
  • Croatia (new proposed treaty)
  • Hungary (new proposed treaty & terminated old treaty)
  • Japan (new protocol)
  • Luxembourg (new protocol)
  • Poland (new proposed treaty)
  • Spain (new protocol)
  • Switzerland (new protocol)

For more information, see our treaty updates page

Tags: 894 Treaties, Other - Resources

Recent Publications


Below are several interesting authorities or publications related to international tax that have been released recently.

The U.S. Senate Permanent Subcommittee on Investigations (PSI), held a hearing on July 30, 2015 exploring the impact of the U.S. corporate tax code on foreign acquisitions of U.S. businesses and the ability of U.S. businesses to expand by acquisition.  The associated report, "Impact of the U.S. Tax Code on the Market for Corporate Control and Jobs," details transactions involving Burger King, Anheuser-Busch, and Valeant.

Notice 2015-54 - Announces that the Treasury Department and the IRS intend to issue regulations under Code §721(c) to ensure that, when a U.S. person transfers certain property to a partnership that has foreign partners related to the transferor, income or gain attributable to the property will be taken into account by the transferor either immediately or periodically.  This notice also announces that the Treasury Department and the IRS intend to issue regulations under Code §§482 and 6662 applicable to controlled transactions involving partnerships to ensure the appropriate valuation of such transactions.

Rev. Proc. 2015-40 - Provides guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority, acting through the Advance Pricing and Mutual Agreement Program and the Treaty Assistance and Interpretation Team of the Deputy Commissioner (International), Large Business & International Division of the Internal Revenue Service.  This revenue procedure updates and supersedes Rev. Proc. 2006-54, and is being issued concurrently with Rev. Proc. 2015-41, which provides guidance with respect to advance pricing agreements.

Rev. Proc. 2015-41 - Provides guidance on the process of requesting and obtaining advance pricing agreements from the Advance Pricing and Mutual Agreement program (“APMA”), a constituent office of the U.S. competent authority, within the office of the Deputy Commissioner International, Large Business & International Division.  This revenue procedure also provides guidance on administration of executed APAs.

The IRS also released two new International Practice Units: Non-Services FDAP Income and Branch-Level Interest Tax Concepts.

Tags: 701 Partnerships, Authority - Notices, Authority - Revenue Procedures, Other - Resources

New Resource Page: Monetary Penalties for Failure to File Common U.S. International Tax Forms


Today we have added a new link in the "Resources" section of the blog: monetary penalties for failure to file common U.S. international tax forms.  The table includes the general civil penalties for failure to file the forms.  Other penalties, such as denial of deductions and criminal penalties are not in the table. 

The resources section is located on the right hand side of the page just below Tax Blogs.  

Tags: Other - Resources

New Addition to the Blog: Resource Pages


We have added a new "Resources" section to the blog, located on the right hand side of the page just below Tax Blogs.  Thus far we have added pages with links to the common U.S. international tax forms as well as the I.R.S. publications on international subjects.  We plan to add more resource pages.  We will let you know as we do.

Tags: Other - Resources