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UK South Africa double tax treaty - new protocol being introduced
  • Landwell
  • South Africa, United Kingdom
  • November 22 2011

South Africa is changing its system of taxing dividends paid to non-residents and introducing withholding tax (WHT


The latest interpretation of the Technical Service Fees article under relevant Double Tax Treaties concluded by China
  • Landwell
  • China, India, Pakistan, United Kingdom
  • May 20 2011

There are a few Double Tax Treaties ("DTTs") concluded by China, namely the DTTs with UK, India and Pakistan (referred as "relevant DTTs" hereafter), which include a specific article on Technical Service Fees


US tax treaty developments
  • Landwell
  • USA
  • October 17 2011

The Senate Foreign Relations Committee on July 26, 2011 approved the new US-Hungary tax treaty and protocols to the Luxembourg and Switzerland treaties, with the recommendation that all three pacts be approved


NlPanama tax treaty
  • Landwell
  • Netherlands, Panama
  • November 22 2011

The tax treaty that the Netherlands signed with Panama on October 6, 2010 has been sent to the House of Representatives


Preferential tax policies for China’s Western Region
  • Landwell
  • China
  • October 17 2011

One of the attractive tax incentives in China is a reduced corporate income tax of 15 for qualified enterprises in encouraged industries incorporated in designated Western Regions, as opposed to the standard CIT rate of 25


President Obama proposes $1.5 trillion in new taxes and calls for comprehensive tax reform
  • Landwell
  • USA
  • October 17 2011

On September 19, 2011 the Obama Administration released The President’s Plan for Economic Growth and Defi cit Reduction, which proposes a 10-year, $3.6 trillion defi cit reduction plan that includes several international and other business tax increases


Senators Hagan and McCain introduce Foreign Earnings Reinvestment Act
  • Landwell
  • USA
  • October 17 2011

On October 6, 2011 Senators Kay Hagan and John McCain introduced a temporary dividend repatriation amendment to the job creation legislation the Senate is expected to address shortly


IRS memo provides insights into IRS thinking on use of Schedule UTP during exams
  • Landwell
  • USA
  • October 17 2011

A memorandum issued August 31, 2011 by Heather Maloy, Commissioner of the IRS’s Large Business & International Division to examination teams assigned to the Compliance Assurance Process Program, addresses examiners’ use of Schedule UTP, Uncertain Tax Position Statement


IRS increases scrutiny of inter-company debt arrangements
  • Landwell
  • USA
  • October 17 2011

The IRS has always been concerned with issues of thin capitalization, debt versus equity characterization and interest deductibility


Senator Reid introduces a revised Obama Jobs Act
  • Landwell
  • USA
  • October 17 2011

On October 5, 2011 Senate Majority Leader Harry Reid introduced a revised version of the Obama Administration’s American Jobs Act