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Senate Foreign Relations considers Chile tax treaty

RFP
Tax Hot Topics newsletter 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:
David Sites
Partner
Washington National Tax Office
T +1 202 861 4104

Cory Perry
Partner
Washington National Tax Office
T +1 202 521 1509

Dustin Stamper
Managing Director
Washington National Tax Office
T +1 202 861 4144

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