Austria

· Letter to Judith Herdin-Winter, Austrian Federal Ministry of Finance, regarding Tax Reclaim Services on Austrian Dividend Payments, July 23, 2014

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, Directorate-General for Taxation and Customs Union, regarding Consultation on tax problems faced by EU citizens when active across borders within the EU, July 3, 2014

· Letter to Commissioner Algirdas Šemeta, European Commission, regarding Financial Transaction Tax, January 9, 2013

· 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 Madame Maylis COUPET, Chef du Bureau Epargne et Marché financier and Monsieur Antoine MAGNANT, Direction de la Législation Fiscale, regarding French Financial Transaction Tax, July 13, 2012

· 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 John Sweeney, Internal Revenue Service, regarding Proposed FATCA FAQ for Umbrella Fund/Sub-Fund Issue, December 24, 2014

· Letter to Ronald Gootzeit, Internal Revenue Service, regarding Reimbursement/Set-Off Procedure under Section 1446, September 30, 2014

· Letter to Yvette Lawrence, Internal Revenue Service, regarding Comments on Form 8802 (Application for United States Residency Certification), May 16, 2013

· Letter to John Sweeney, Internal Revenue Service and Michael H. Plowgian, United States Treasury, regarding Overlap between FATCA Reporting under Chapter 4 and US Payor Reporting under Chapter 61 of the Internal Revenue Code, November 30, 2012

· Letter to John Sweeney, Internal Revenue Service and Michael H. Plowgian, United States Treasury, regarding Follow-Up to July 19, 2012 Meeting on Proposed FATCA Regulations under Sections 1471-1474 of the Internal Revenue Code, September 7, 2012

· Letter to John Sweeney, Internal Revenue Service, regarding Comments on Proposed FATCA Regulations under Sections 1471-1474 of the Internal Revenue Code, April 30, 2012

· Letter to Messrs. Mark E. Erwin and D. Peter Merkel, Internal Revenue Service, regarding Comments on Temporary Dividend Equivalent Regulations under Section 871(m) of the Internal Revenue Code, March 29, 2012

· 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 Internal Revenue Service and the U.S. Department of the Treasury, regarding Comments on Foreign Account Tax Compliance Act (FATCA) Provisions of the Hiring Incentives to Restore Employment (HIRE) Act, September 8, 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 Director of International Tax Policy and Legislation, Ministry of Finance, International Tax Policy and Legislation Directorate, regarding Association of Global Custodians - Request for Mutual Agreement Procedure under Article 26 of the Italy - Netherlands Income Tax Treaty, September 26, 2012

· 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 Mr. Dae-Young Kwon, Financial Services Commission, regarding US-Korea FATCA Agreement – Definition of “Account Holder” in the Context of Sub-Custody Accounts, March 25, 2014

· Coalition Letter to Mr. Seunghee Han, Assistant Commissioner for International Tax Bureau, National Tax Service, and Mr. Byung-Sik Jung, Director of International Tax Division, Ministry of Strategy and Finance, regarding Administrative Obstacles Effectively Preventing CIVs from Receiving Tax Treaty Relief, October 22, 2012

· 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

Organisation for Economic Co-operation and Development ("OECD")

· Letter to Marlies de Ruiter, OECD, regarding OECD Discussion Draft – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, April 9, 2014

· Letter to Achim Pross and Philip Kerfs, OECD, regarding Multilateral Automatic Exchange of Information and TRACE, July 26, 2013

· 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

Philippines

· Letter to Commissioner Kim S. Jacinto-Henares, Philippine Bureau of Internal Revenue, regarding Taxpayer Identification Number (TIN) Requirement, July 25, 2014

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

 

 

 

© Association of Global Custodians – 2003 All Rights Reserved

Legal Notices - Disclaimer