tag:blogger.com,1999:blog-9208928.post3879848271881408179..comments2024-03-29T03:16:05.261-04:00Comments on Start Making Sense: Ten quick observations on the Made in America Tax PlanDaniel Shavirohttp://www.blogger.com/profile/14710628584922961682noreply@blogger.comBlogger7125tag:blogger.com,1999:blog-9208928.post-16870078154043520632022-05-01T12:05:19.409-04:002022-05-01T12:05:19.409-04:00URGENT LOAN IS AVAILABLE NOW
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Doesn't it make a difference if the fore...Dan,<br /><br />Doesn't it make a difference if the foreign country/tax haven has a tax treaty with the US or not. If there is no tax treaty in place yes the determination of corporate residence, source-based rights, deductions, etc. are a matter determined solely by US domestic law but if a treaty is in place between the US and the other jurisdiction then the Biden Administration and Congress face a far more difficult political decision.<br /><br />FATCA in some sense worked as it wasn't a "true" override of any tax treaty only a shift in how withholding taxes were administered and the US since it negotiated its first tax conventions decades ago has always inserted a "savings clause" giving it the right to tax the residents of the treaty partners country who are deemed US persons as a matter of US domestic law.<br /><br />The issue is not so much that some small "tax haven" breaks ranks but a tax treaty partner and perhaps a quite significant tax treaty partner breaks ranks of the minimum tax proposal. Timhttps://www.blogger.com/profile/03894651289037073128noreply@blogger.comtag:blogger.com,1999:blog-9208928.post-29834128112136705952021-04-10T04:45:54.179-04:002021-04-10T04:45:54.179-04:00Do you need Personal Finance?
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