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Brazil
· Letter to Mr. Amauri Bier, Executive Secretary of the Finance Ministry and Mr. Francisco de Assis de
Guimarães de Paula, Secretaria da Receita
Federal, regarding: CPMF
Tax - Letter to Ministry of Finance,
August 8, 2002 Canada
·
Letter to Mr. Wayne Adams, Director General and Mr. Jim Gauvreau, Director
Competent, Canada Revenue Agency, regarding:
Canada-France Income Tax Treaty and Canadian Mutual Funds Trusts & Pooled
Funds Trusts, July 2,
2004 Colombia
·
Letter to
Sra. Jeanette Forigua Rojas, Portfolios de Inversion y Otoros Agentes,
regarding Monthly Withholding Tax on Fixed Income Securities for Foreign
Investment Funds,
December 21, 2010 European
Union Institutions
·
Letter to the European Commission (sent
jointly with the AGC, BBA and AFME), regarding Consultation on Taxation
Problems That Arise When Dividends are Distributed Across Borders to
Portfolio and Individual Investors and Possible Solutions, April 28, 2011
·
Letter to
Frederica Liberatore, European Commission, regarding Custodian Working
Group Executive Briefing Paper: Outstanding Italian Tax Refunds --
Points for Discussion, April 11, 2011 France
·
Letter to Jeffrey Owens, Director, CTPA, Organisation for Economic
Co-operation and Development, regarding OECD Discussion Draft -
Clarification of the Meaning of "Beneficial Owner" in the OECD Model Tax
Convention, July 13, 2011
·
Letter to Benedetta A. Kissel, Esq., Deputy International Tax Counsel
(Strategic Programs) U.S. Department of the Treasury, regarding:
U.S.-France Income Tax Treaty Issue, August 27, 2007
· Letter to
M. Vincent Mazauric, Direction de la Legislation Fiscale, regarding:
French Tax Relief Issues for Non-Individual Beneficiaries, February 10,
2004
G30
·
Letter to
Chris Gilbert, Vice President - Investor Services, JPMorgan Chase Bank,
N.A.,
regarding: Proposed Tax Relief Model - A Response to G30 Recommendation 8,
June 17, 2005
Greece
·
Letter to
Greek Tax Authorities regarding Potential Capital Gains Regime (in English
and Greek),
September 9, 2009
Indonesia
·
Letter to
Dr. Achmad Sjarifuddin Alsah, Head Office of Directorate General of Taxes,
regarding Regulations PER-40/PJ/2010, PER-61/PJ/2009 and PER-62/PJ/2009,
January 6, 2010 Ireland
·
Letter to Mr. Gary Palmer, Chief Executive, Dublin Funds Industry
Association, regarding Inconsistent Global Tax Treatment of Irish
Undertakings for Collective Investment in Transferable Securities,
March 27, 2006
·
Letter to Ms. Marie Hurley and Ms. Susan Cummins, Direct Taxes,
Interpretation and International Division, Irish Revenue Commissioners, regarding:
Follow-Up on the Inconsistent Global Tax Treatment of Irish UCITs, June
28, 2005
·
Letter to Ms. Marie Hurley and Ms. Susan Cummins, Direct Taxes,
Interpretation and International Division, Irish Revenue Commissioners, regarding:
Inconsistent Global Tax Treatment of Irish UCITs, June 4, 2004
IRS
·
Letter to
Michael Danilack, Internal Revenue Service, regarding Association of
Global Custodians: Request for Competent Authority Assistance Under
Article 25 of United States - Italy Income Tax Treaty,
February 8, 2011
·
Letter to
Internal Revenue Service, regarding Comments on
Notice 2010-60 and on Foreign Account Tax Compliance Act (FATCA)
Provisions of the Hiring Incentives to Restore Employment (HIRE) Act,
November 29, 2010
·
Letter to
Stephen Schaeffer, Internal Revenue Service, regarding Comments on
Proposed Costs Basis Reporting Regulations, August 27, 2010
·
Letter to
Courier Desk, Internal Revenue Service,
regarding Custodian Withholding Obligations With Respect to Distributions
by Publicly Traded Partnerships - Need for Guidance, March 22, 2010
·
Letter to
Stephen Schaeffer, Internal Revenue Service,
regarding Reporting of Adjusted Basis in Securities Transactions - Notice
2009-17, April 20, 2009
·
Letter to U.S. Department of the Treasury and Internal Revenue Service,
Commenting on CC:PA:LPD:PR (REG-140206-06); Proposed Regulation Section
1.1441-3, January 22, 2008
·
Letter to Frank Ng and Tina Byrd, IRS, from the AGC, DTC, SIA Dividend
Division and the Clearing House Association, regarding Proposed Mutual
Agreements Defining Eligibility for Treaty Benefits: Denmark,
Germany, Finland, and Sweden,
November 13, 2006
·
Letter to Commissioner Mark Everson, IRS, regarding Urgent Request for
Delay in Implementation of User Free for Processing of Treaty Residency
Certifications,
September 28, 2006
·
Letter to Aziz Benbrahim, Tax Treaty Group Manager, International Tax
Treaty Division, Internal Revenue Service, regarding:
July 25, 2005 Meeting with the Association of Global Custodians,
September 2, 2005
·
July 25, 2005 Meeting with the Association of Global Custodians,
September 2, 2005
·
Letter to Curtis G. Wilson, Assistant Chief Counsel, Administrative
Provisions and Judicial Practice, Internal Revenue Service and Harry J.
Hicks III, Associate Chief Counsel, International, Internal Revenue
Service, regarding:
Form 8802 (Application for U.S. Residency Certification) - Term of
Validity, May 27, 2005
·
Letter to Robert Green, Director, International, Internal Revenue Service,
regarding: Form 8802 (Application for U.S. Residency Certification) - Term
of Validity and Timing of Submission, May 27, 2005
·
Letter to Robert Green, Director, International, Internal Revenue Service, regarding:
Request for Mutual Support, January 11, 2005
·
Letter to Robert Green, Director, International, Internal Revenue Service, regarding:
U.S. Residency Certification--Forms 6166 and 8802, July 30, 2004
·
Letter to Robert Green, Director, International and Elvin Hedgpeth, Deputy
Director, International, Office of Tax Treaty, Internal Revenue Service, regarding:
Form 8802 and Related Procedures, April 13, 2004
Italy
·
Letter to
Michael Danilack, Internal Revenue Service, regarding Association of
Global Custodians: Request for Competent Authority Assistance Under
Article 25 of United States - Italy Income Tax Treaty,
February 8, 2011
·
Letter to
Italian Authorities regarding Unpaid Claims on Withheld Tax (in English
and Italian),
September 18, 2009
·
Letter to Dott Gianni Giammarino, Direttore Centrale Gestione Tributi, regarding:
Italian Tax Repayment Issues, May 11, 2004
Japan
· Letter to Keiji Aoyama, Deputy Commissioner
(International Affairs), National Tax Agency, regarding: Follow-up on the Requirements to
Comply with the New U.S./Japan Tax Treaty, February 22, 2005
· Letter to Keiji Aoyama, Deputy Commissioner
(International Affairs), National Tax Agency, regarding: Requirements to
Comply with the New U.S./Japan Tax Treaty, September 15, 2004
Korea
· Letter to Byung-Cheol Kim, Director,
Corporation Tax Division, Ministry of Strategy and Finance, regarding
Article 98-6 of the Corporate Income Tax Law and Draft Presidential Decree
Article 138-7, Special Cases of Tax Withholding Procedures for Application
of Reduced Tax Rates pursuant to Double Tax Treaties for Foreign
Corporations, January 19, 2012
· Letter to
Jae-wan Bahk, Minister of Strategy and Finance and Hyun-dong Lee,
Commissioner, National Tax Service, Republic of Korea, regarding The
Status of Luxembourg SICAVs and SICAFs regarding Reduced Rates of Korean
Withholding Tax under the Applicable Double Tax Treaty, June 24, 2011
·
Letter to
Guy Heintz, Administration des Contributions Directes/Ministere des
Finances, regarding The Status of Luxembourg SICAVs and SICAFs regarding
Reduced Rates of Korean Withholding Tax under the Applicable Double Tax
Treaty, June 7, 2011
Luxembourg
· Letter to
Jae-wan Bahk, Minister of Strategy and Finance and Hyun-dong Lee,
Commissioner, National Tax Service, Republic of Korea, regarding The
Status of Luxembourg SICAVs and SICAFs regarding Reduced Rates of Korean
Withholding Tax under the Applicable Double Tax Treaty, June 24, 2011
·
Letter to
Guy Heintz, Administration des Contributions Directes/Ministere des
Finances, regarding The Status of Luxembourg SICAVs and SICAFs regarding
Reduced Rates of Korean Withholding Tax under the Applicable Double Tax
Treaty, June 7, 2011
Norway
·
Letter to
Johanne Rian, Legal Adviser, The Royal Norwegian Ministry of Finance, regarding:
Treaty Eligibility Under Norway-U.S. Income Tax Convention, February
28, 2009
·
Letter to Elisabet A. Landmark, Director, Norwegian Directorate of Taxes, regarding:
Norwegian Dividend Withholding Tax Exemption, July 17, 2007
Poland
·
Letter to Mariusz Zygierewicz and Norbert Jeziolowicz, Zwiazek Bankow
Polskich, regarding Issues Raised by Interpretations of Recent Amendments
to the Corporate Tax Law in Poland, April 22, 2011 Portugal
·
Letter to
Exmo. Senhor Prof. Sergio Vasques, Ministerio das Financas, regarding Tax
Relief Arrangements on Portuguese Securities, March 4, 2011
·
Letter to Ministro das Financas, Professor Doutor Fernando Teixeira dos
Santos, regarding:
Administrative Tax Relief Arrangements on Portuguese Securities, July
17, 2007
·
Letter to Maria Manuela Dias Ferreira Leite, Ministra de Estado e das
Financas, regarding:
Portuguese Tax Relief Issues, March 5, 2004 |