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

France

· 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

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 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 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

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

Portugal

· 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

 

 

 

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