Table of Contents
New tax treaties and protocols. The United States has exchanged instruments of ratification for a new income tax treaty with Belgium and new protocols for the income tax treaties with Denmark, Finland, and Germany. The provisions of these treaties and protocols are included in the appropriate areas of this publication. The effective dates are as follows: Belgium. The provisions relating to withholding tax at source are effective for amounts paid or credited on or after February 1, 2008. For other taxes, the treaty is effective for tax periods beginning on or after January 1, 2008. A person entitled to benefits under the previous treaty can elect to have that treaty apply in its entirety for a twelve-month period following the date the new treaty would otherwise apply. Denmark. The provisions relating to withholding tax at source are effective for amounts paid or credited on or after February 1, 2008. For other taxes, the protocol is effective for tax periods beginning on or after January 1, 2008. Finland. The provisions relating to withholding tax at source are effective for amounts paid or credited on or after February 1, 2008. However, the provisions for dividends exempt under Article 10(3) as amended by this protocol are effective January 1, 2007. For other taxes, the protocol is effective for tax years beginning on or after January 1, 2008. Germany. The provisions relating to withholding tax at source are effective for amounts paid or credited on or after January 1, 2007. For other taxes, the treaty is effective for tax years beginning on or after January 1, 2008. A person entitled to benefits under the treaty before modification by this protocol can elect to have the unmodified treaty apply in its entirety for a twelve-month period following the date the protocol would otherwise apply.
Disclosure of a treaty-based position that reduces your tax. If you take the position that any U.S. tax is overruled or otherwise reduced by a U.S. treaty (a treaty-based position), you generally must disclose that position on your affected return. See Application of Treaties, later.
U.S.-U.S.S.R. income tax treaty. The U.S.-U.S.S.R. income tax treaty remains in effect for the following members of the Commonwealth of Independent States: Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these individual countries are negotiated and ratified. Provisions of the U.S.-U.S.S.R. income tax treaty are discussed in this publication under Commonwealth of Independent States.
U.S.-China income tax treaty. The U.S.-China income tax treaty does not apply to Hong Kong.
U.S.-United Kingdom income tax treaty. Generally, the treaty is effective for tax periods beginning on or after January 1, 2004. However, an individual who was otherwise entitled to treaty benefits under Article 21 (students and trainees) of the former treaty can continue to apply that provision.
U.S.-Japan income tax treaty. Generally, the treaty is effective for tax periods beginning on or after January 1, 2005. However, an individual who was entitled to treaty benefits under Article 19 (teachers and researchers) or Article 20 (students and trainees) of the former treaty as of March 30, 2004, can continue to apply those provisions.
This publication will tell you whether a tax treaty between the United States and a particular country offers a reduced rate of, or possibly a complete exemption from, U.S. income tax for residents of that particular country.
Tables in the back of this publication show the countries that have income tax treaties with the United States, the tax rates on different kinds of income, and the kinds of income that are exempt from tax.
You should use this publication only for quick reference. It is not a complete guide to all provisions of every income tax treaty.
Internal Revenue Service
Individual Forms and Publications Branch
SE:W:CAR:MP:T:I
1111 Constitution Ave. NW, IR-6526
Washington, DC 20224
Department of the Treasury
Office of Public Correspondence
1500 Pennsylvania Ave. NW — Rm. 3419
Washington, D.C. 20220
Internal Revenue Service
International Returns Section
P.O. Box 920
Bensalem, PA 19020-8518
Publication
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519 U.S. Tax Guide for Aliens
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597 Information on the United States-Canada Income Tax Treaty
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686 Certification for Reduced Tax Rates in Tax Treaty Countries
Form (and Instructions)
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8833
Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b)
See How To Get Tax Help near the end of this publication for information about getting these publications and forms.
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