American Payroll Association (APA) Basic Guide to Payroll, 2013 Edition
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Expanding the U.S. tax treaty network is a high priority, Emily McMahon, Acting Assistant Treasury Secretary for Tax Policy, said on June 20 at an event sponsored by the District of Columbia Bar Association. “The U.S. has a network of almost 60 comprehensive tax treaties and a growing number of tax information exchange agreements,” McMahon said. Tax information exchange agreements, she explained, have been utilized with jurisdictions that have little or no tax and there is no need for a comprehensive tax treaty with these jurisdictions. McMahon reported that three tax treaties are currently awaiting action in the Senate. The U.S. has negotiated new protocols to the existing tax treaties with Luxembourg and Switzerland. An updated comprehensive tax treaty with Hungary is also awaiting Senate action.
In addition, a comprehensive tax treaty with Chile was sent to the Senate. “Expanding our treaty network in Latin America is a high priority,” McMahon stated. Businesses, she noted, are eager for expansion of bilateral tax treaties with countries in South America. Further, negotiations are continuing on protocols to existing treaties with Japan and Spain. Tax treaty negotiations typically unfold over a long period of time, McMahon explained. “A new tax treaty usually takes two or three rounds of negotiations separated by six months or more. There are many examples of treaty negotiations that unfold over multiple years.”
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