International Tax Blog

Canada & U.S. to Apply the Authorized OECD Approach (“AOA”) for Attribution of Business Profits

In the recently released Announcement 2012-31, the IRS announced that the competent authorities of the U.S. and Canada entered into an agreement regarding the application of Article VII (Business Profits) of the Canada-U.S. Income Tax Treaty (the “Treaty”). Paragraph 9 of Annex B of the Treaty refers to the applicability of the OECD Transfer Pricing Guidelines, by analogy, for the purposes of determining the business profits attributable to a permanent establishment. The OECD Report on... Read more →

Belgian Municipal and Conurbation Income Taxes are Covered by the Treaty

In the recently released Announcement 2012-30, the IRS announced that the U.S. and Belgian competent authorities have agreed that Belgian municipal and conurbation income taxes are included in the income taxes covered under Article 2, Paragraph 3(a) of the Belgium-U.S. Income Tax Treaty. “Conurbation” is a new word for me. According to my dictionary it means “an extensive urban area resulting from the expansion of several cities or towns so that they coalesce to retain... Read more →