US Inbound Corner

US Inbound Corner is a bulletin of the latest tax developments affecting businesses investing into the United States. Written by professionals of the Deloitte member firms, the newsletter provides invaluable insights on a broad range of topics affecting US inbound taxpayers.​

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July 2015

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July 2015

Unforeseen Difficulties to Analyzing US Income Tax Treaties through the Derivative Benefits Provision: US income tax treaties can often times be compared to snowflakes. While all of them are quite similar in structure and purpose, no two are exactly alike. This is especially true when evaluating the limitation on benefits article in modern US treaties and the strict language of many recent derivative benefits provisions, which may surprise those unfamiliar with these limitations. This article highlights the complexities of evaluating the limitation on benefits in modern US treaties.

BEPS Action 13: Country-by-Country Reporting Implementation Package: On 8 June 2015, the OECD, as part of the G20/OECD work on the action plan to address base erosion and profit shifting (BEPS), released Action 13: Country-by Country Reporting Implementation Package. The implementation package outlines model legislation that governments can use to adopt the new rules, as well as competent authority agreements to implement the sharing mechanisms for the Country-by-Country report.

US Sales and Use Tax: A survival guide for international business: Foreign companies are oftentimes caught off guard by the differences between US sales and use tax and international value added taxes. As different states have different rules, figuring out which taxes are due to whom can seem quite overwhelming. In this article, approaches and tools are discussed that businesses can use to proactively understand and take command of their US sales and use tax obligations.

Recent Developments Which May Affect Inbound Companies: Recent guidance issued by the IRS may affect inbound companies operating in the US in various areas of the tax laws. Companies should be aware of this guidance and consider how they may be impacted.

Country Spot Light: Japan: The 2015 tax reform proposals in Japan were enacted on 31 March 2015. This article provides a short list of significant proposals that may affect foreign based companies doing business in Japan and foreign nationals working in Japan.

Calendars to watch: Each edition, be sure to mark your calendars for some of the more important events (recent and upcoming) as well as tax developments making in impact on businesses investing into the United States.

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