Income Tax Treaties, Agreements, and MLI

Information to assist multinationals apply income tax treaties to cross-border activities and transactions

Manal Corwin

Manal Corwin

Principal in Charge, Washington National Tax, KPMG LLP (U.S.)

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News and updates from KPMG LLP (KPMG) on U.S. income tax treaties and the Organisation for Economic Co-operation and Development's (OECD's) Multilateral Instrument

 

U.S. Tax Treaties

Current Status of  U.S. Tax Treaties and International Tax Agreements, a montly article by KPMG Tax professionals published in Tax Management International Journal, catalogues the current status of U.S. tax treaties and international tax agreements, including:

  • Income tax treaties
  • Estate/gift tax treaties
  • Tax information exchange agreements (TIEAs)
  • FATCA intergovernmental agreements (FATCA IGAs)
  • Reciprocal shipping/aviaiton agreements
  • Social secuirty totalization agreements.

Current Status of U.S. Tax Treaties and International Tax Agreements
May 10, 2019 | This article catalogs the current status of U.S. tax treaties and international tax agreements as of April 26, 2019.

U.S. Income Tax Treaties – Eligibility for Treaty Benefits

The following articles by KPMG Tax professionals were published by Tax Analysts in Tax News International. The articles provide flowcharts to assist practitioners in determining a company's eligibility for treaty benefits under the limitation on benefits provisions of the specific U.S. income tax treaties and, where applicable, in determining eligibility for a 0 percent withholding tax rate on cross-border intercompany dividend payments to the company.

* Based on treaty protocol.

OECD's Multilateral Instrument

BEPS Action 15 - MLI: Country Implementation Summary
This document provides an overview of countries that intend to sign on, or have already signed on the OECD's BEPS Action 15 Multilateral Instrument, as of April 9, 2019.