|
|
Austria
· Letter to Judith Herdin-Winter, Austrian
Federal Ministry of Finance, regarding Tax Reclaim Services on Austrian
Dividend Payments, September 3, 2015
· 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 Canada Revenue Agency Requesting Improvements to Withholding Tax
Procedures for Canadian Securities Held Through Depository Trust Company,
February 5, 2020
·
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
Denmark
·
Letter to Denmark on Proposed Relief at Source System,
December 21, 2018
·
Letter to Denmark on Proposed Relief at Source System, August 20, 2018
Depository Trust Corporation
·
Letter to Depository Trust Corporation on Withholding Procedures for
Canadian and Puerto Rican Securities, May 1, 2019
European
Union Institutions
·
Letter
to the European Commission regarding
Public Consultation on Cross-Border Distribution of Investment Funds,
November 15, 2016
· 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
Finland
·
Letter to Finnish Tax Administration on Issues of Concern to Potential
Authorised Intermediaries Under Final Guidance on “Authorised
Intermediary’s Responsibilities and Liabilities” and Revised Draft
Guidance on “Intermediary Self-Declarations”, September 4, 2020
·
Letter to Finnish Tax Administration on Consultation on Draft 'Authorised
Intermediary Responsibilities and Liability' Guidance, June 12, 2020
·
Letter to Finnish Tax Administration on Consultation on Draft 'Investor
Self-Declaration and Verifying its Reliability' Guidance, May 22, 2020
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
India
·
Letter to Indian Central Board of Direct Taxes regarding Introduction of
Dividend Withholding Tax under Budget 2020, March
27, 2020
Indonesia
·
Letter to Indonesian Directorate General of Taxation regarding Request for
Clarification on Regulation Number PER-25/PJ/2018 (Revising the Anti-Tax
Treaty Abuse Rules), January 2, 2020
·
Letter to
Indonesian Directorate General
of Taxation regarding Request for Clarification on Regulation Number
PER-10/PJ/2017 and Forms DGT-1 and DGT-2, September 25, 2017
·
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 Irish Revenue regarding Consultation on Real-Time Reporting for
Dividend Withholding Tax, December 10, 2019
·
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
Internal Revenue Service regarding Form 8802, Application for
Certification of U.S. Residency, March 30, 2018
·
Letter to
Internal Revenue Service regarding Temporary Regulations Requiring Foreign
TIN and Date of Birth Information on Form W-8BEN, April 5, 2017
·
Letter to
Internal Revenue Service regarding Proposed Regulations on the Automatic
Extension of Time to File Form 1042-S under Temporary Treasury Regulation
section 1.6081-8T, January 21, 2016
·
Letter to Commissioner John
Koskinen, Internal Revenue Service, et al., regarding Section 1441
Withholding Procedures for Certain Distributions to Which Section 302
Applies, December 9, 2015
· Letter to
John Sweeney, Internal Revenue Service, regarding Proposed FATCA FAQ on
Validity of Print-outs of Electronically Signed Forms W-8 and W-9, May 27, 2015
· 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
·
CIV Industry Coalition Letter to Korean Ministry of Strategy and Finance
on Impact of Korean Capital Gains Tax on Non-Korean CIVs,
January 27, 2018
·
Letter to Korean Ministry of Strategy and Finance on Korea's Capital Gains
Tax Changes for Foreigners,
January 27, 2018
·
Letter to Marlies de Ruiter, OECD, regarding OECD
Revised Discussion Draft, BEPS Action 6 - Preventing Treaty Abuse,
June 16, 2015
·
Letter to Marlies de Ruiter, OECD, regarding OECD Discussion Draft,
Follow-Up Work on BEPS Action 6 - Preventing Treaty Abuse,
January 9, 2015
·
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")
·
Joint
Trade Association Letter to OECD and EC on COVID-19 Withholding Tax
Challenges, September 3, 2020
·
Joint Trade Association Letter to OECD and EC on COVID-19 Withholding Tax
Challenges, April 20, 2020
·
Letter to Marlies de Ruiter, OECD, regarding OECD Discussion Draft,
The Treaty Residence of Pension Funds,
April 1, 2016
·
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
Philippines Secretary of Finance Carlos Dominguez on the Passive Income
and Financial Intermediary Taxation Act (“PIFITA”), November 18, 2019
·
Letter to Ms. Trinidad A. Rodriguez, National Tax Research Center of the
Philippines, regarding Recommendations for Development of Tax Reform
Proposals Under TRAIN 4 and Requests for Clarification of RMO No. 8-2017,
December 6, 2017
·
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
U.S. Treasury
·
Letter to
Danielle E. Rolfes, United States Treasury, regarding Draft Provisions for
the U.S. Model Income Tax Treaty, September 11, 2015
|