Tax Procedure: A Look at the U.S. Role in Collecting Foreign Taxes

united-states-and-canadaThe United States has entered into bilateral tax treaties with a significant number of countries. The general goal of these arrangements is to increase trade by eliminating double taxation. As a consequence, they have rules to determine the residence of taxpayers and provisions limiting the ability of the treaty partners to impose taxes in certain cases.

A few of these treaties include provisions for collection assistance; earlier this year, a district court addressed a challenge to a request for collection assistance received from the Kingdom of Denmark. See Dileng v. Comm’r, 157 F. Supp. 2d 1336 (N.D. Ga. 2016). Recently, a district judge in North Carolina addressed the collection assistance provisions of the U.S.-Canada treaty.… Read More

A Level Playing Field: A Challenge to Special Treatment of Section 501(c)(3) Applications Moves Forward.

Qualification as a tax-exempt entity under Section 501(c)(3) of the Internal Revenue Code carries a variety of benefits, including the ability of donors to claim a deduction for contributions. To qualify for these benefits, an entity will file an application requesting that the IRS determine that it is entitled to tax exempt status under Section 501(c)(3).
Last week, the United States District Court for the District of the District of Columbia issued a very interesting opinion dealing with a claim that a particular entity seeking tax exempt status was subjected to special procedures due to the views that it espoused. Z Street, Inc.Read More