The Senate Foreign Relations Committee has scheduled a hearing on March 29 to consider a tax treaty with Chile.
The treaty was originally signed in 2010, but languished for years unratified over objections from Sen. Rand Paul, R-Ky., along with tax treaties for Hungary and Poland and four tax treaty protocols. The Senate finally overcame Paul’s objections and ratified the four protocols in 2019, but the three treaties were held up due to complications arising from the enactment of the Tax Cuts and Jobs Act.
The treaties need reservations—text or statements addressing non-compliance on certain provisions—to account for the enactment of the base-erosion and anti-abuse tax since they were written. Reservation language has been drafted for the treaty with Chile, though it remains unclear if there is enough Senate support for ratification. The tax treaties for Hungary and Poland would also need reservations, and the Foreign Relations Committee has not scheduled either for consideration.
Contacts:
Tax professional standards statement
This content supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the topics presented herein, we encourage you to contact us or an independent tax professional to discuss their potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this content may be considered to contain written tax advice, any written advice contained in, forwarded with or attached to this content is not intended by Grant Thornton LLP to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.
The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice provided by Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact Grant Thornton LLP or other tax professionals prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton LLP assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.
More tax hot topics
No Results Found. Please search again using different keywords and/or filters.