Income tax treaties can provide significant protections for European investors and businesses in the US. As Congress seeks to close tax loopholes, to generate additional revenue, users of US tax treaties may face even tighter anti-treaty-shopping rules, warn Alfred Groff, Kristen Garry and Nathan Tasso, of Shearman & Sterling.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap