Minor Memos. The US Treasury is being urged to waive withholding taxes on dividends that US companies pay to shareholders in the United Kingdom. A tax treaty between the two countries bars the United States from collecting withholding taxes on dividends paid to UK shareholders, but only to UK shareholders who own at least 80% of the US company directly. The US Treasury is being asked to allow indirect shareholders also to benefit. This would let a UK company that owns at least 80% of the US shares, but through more than one subsidiary, benefit from the treaty. If the US Treasury relents, then the same principle should apply to US outbound investment into the United Kingdom .... The US Tax Court said in May that large gasoline tanks that last more than 60 years and weigh up to a million pounds are not “inherently permanent structures” for US tax purposes. The conclusion means that the tanks can be depreciated over five years. The case is PDV America v. Commissioner.

Keith Martin