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	Tax treaty - Wikipedia, the free encyclopedia
		Tax treaties exist between many countries on a bilateral basis to prevent double taxation (taxes levied twice on the same income, profit, capital gain, inheritance or other item).
		Tax treaties tend not to exist when either party regards the other as a tax haven, for obvious reasons.
		For example, many tax treaties operate to provide tax relief to a corporate group when a state has imposed a corporate income tax on profits earned by a subsidiary corporation and another state otherwise would impose a corporate income tax on its parent corporation when those profits are distributed as a dividend.
	en.wikipedia.org /wiki/Tax_treaty (588 words)

	The Income Tax Treaty Between the United States and Thailand
		Tax sparing is a form of incentive to investment that usually takes the form of a reduction of tax rates or tax holidays.
		The governments involved consider the tax treaty as an agreement to limit the taxing jurisdiction of each state, with a primary aim being the encouragement of foreign investment or labor or to assist the state’s residents in overseas investments or work-related projects.
		Article 9 permits one contracting state to increase the assessed tax of one of its enterprises in regard to that enterprises dealings with a related enterprise of the other contracting state, thereby causing the other contracting state to make what would normally be a downward adjustment in its assessed tax.
	www.thailawforum.com /articles/taxleeds.html (3682 words)

	OISS: Tax Treaties Between the US and Foreign Governments
		A tax treaty is an agreement between two governments under which each agrees to limit or modify its domestic tax laws in an attempt to avoid double taxation of income.
		An individual who is a resident of a country with which the United States has entered into a tax treaty must look at the provisions of that treaty to determine his or her tax liabilities.
		Treaties are not all the same and the foreign national must review the treaty with his/her country to determine any benefits.
	www.unh.edu /oiss/employment/treaty.html (1306 words)

	U.S. Tax Solutions for Foreign Nationals
		An income tax treaty is an agreement between two countries under which each country agrees to limit the application of its domestic tax laws for residents of the other country.
		New income tax treaties with the republics of Estonia, Latvia, Lithuania and Venezuela entered into force on December 30, 1999, and a new treaty with Slovenia is generally effective beginning in 2002.
		Generally, all of the tax treaties to which the U.S. is a party contain a "saving clause," which is meant to prevent residents of the treaty partner who are also citizens or residents of the U.S. from using the treaty to reduce their U.S. tax liability.
	www.thetaxguy.com /treaties.htm (1324 words)

	ILW.COM - immigration news: Tax Treaty Benefits For Foreign Students (Site not responding. Last check: 2007-10-29)
		Tax treaty benefits for foreign students vary considerably depending upon when the treaties became effective.
		To provide tax treatment similar to U.S. citizens for foreign students, a few tax treaties – Barbados, Jamaica, and Hungary – allow students to elect to be treated as residents.
		The Treasury Explanation for the treaty with the Netherlands notes that: “It is not standard U.S. treaty policy, particularly in treaties with developed countries, to include an earned income exemption for visiting students.” The United States preserves the benefits from prior treaties when they are important to the treaty partner.
	www.ilw.com /lawyers/articles/2005,0225-singer.shtm (750 words)

	: GN 05010.167 - Tax Treaty With Switzerland - 08/31/98 (Site not responding. Last check: 2007-10-29)
		In December 1997, a tax treaty with Switzerland was finalized.
		The terms of this treaty reduced, from 25.5 percent to 15 percent, the nonresident alien tax withheld from the benefits paid to residents of Switzerland.
		The tax treaty is effective for benefits paid on or after February 1, 1998, for months after November 1983.
	policy.ssa.gov /POMS.NSF/lnx/0205010167 (161 words)

	Tax Executive, The: U.S. Model Income Tax Treaty (Site not responding. Last check: 2007-10-29)
		Members of TEI are responsible for managing the tax affairs of their companies and must contend daily with the provisions of the tax law relating to the operation of business enterprises.
		Tax barriers should not impede the flow of goods across borders.(2) To this end, we recommend stronger coordination of treaty partners' rules, especially with respect to sourcing and tax-free reorganizations.
		Asset taxes are designed to provide a stable revenue base for governments in a manner that eliminates the susceptibility of a pure income tax to the economic cycle.
	www.findarticles.com /p/articles/mi_m6552/is_n1_45/ai_13503360 (1356 words)

	Australia and UK sign new tax treaty
		This new Treaty was signed by the Australian and United Kingdom Governments on 21 August 2003, and replaces the existing Treaty and amending Protocol signed in 1967 and 1980 respectively.
		Under the new Treaty, income or gains derived by a resident of one country, which are taxable in the other country, are deemed to be sourced in the other country, for the purposes of that country’s laws.
		Article 22 of the new Treaty provides that where a resident of one country derives income in the other country, relief in the form of a credit must be given against income tax paid on the income sourced in the other country (source country).
	www.ey.com /global/content.nsf/UK/IT_-_Alerts_-_03_08_DC_-_australia_uk_sign (2018 words)

	Frequently Asked Questions - Keyword: Tax Treaty
		Under the 1997 protocol to the Canada - U.S. tax treaty, the Canadian and U.S. governments agreed to return to a residence-based system under which social security benefits are taxable exclusively in the country where the recipient resides.
		If social security tax and Medicare were withheld in error from pay received which was not subject to the taxes, you must first contact the employer who withheld the taxes for reimbursement.
		Therefore, your compensation, unless it is specifically excluded from the term "wages" by law, or is exempt from tax by treaty, is subject to graduated withholding.
	www.irs.gov /faqs/faq-kw196.html (984 words)

	United States-United Kingdom tax treaty enters into force
		UK income taxes (other than those withheld at source) and capital gains taxes, the treaty will have effect for any year of assessment beginning on or after 6 April 2003.
		US taxes other than withholding taxes, the treaty will have effect for tax periods beginning on or after 1 January 2004.
		Taxpayers entitled to benefits under the prior treaty may elect to extend the benefits of that treaty for one year from the date on which the relevant provision of the new treaty would first take effect.
	www.ey.com /global/content.nsf/UK/IT_-_Alerts_-_03_04_DC_-_United_States-United_Kingdom_tax_treaty (280 words)

	Cooley Godward LLP \| News & Publications \| Cooley Alerts \| Tax Treaty Developments
		Interest exempt from withholding tax includes cross-border interest payments to financial institutions, pensions (provided the interest is not directly or indirectly related to carrying on a business) and other creditors to the extent the indebtedness arose as part of the sale of equipment or merchandise on credit.
		Because withholding tax is imposed based on the treaty provisions in effect at the time an item of income is credited or paid and not necessarily when the item of income is accrued, deferring the payment of an item of income accrued before July 1 until after June 30 could result in a tax savings.
		The later provision is particularly important in light of a recent tax assessment made by the Japanese tax authorities who had ruled that a Delaware limited partnership should be treated as a corporation for Japanese income tax purposes and accordingly, denied a Japanese limited partner deductions for his allocable share of the limited partnership's losses.
	www.cooley.com /news/alerts.aspx?id=38549020 (869 words)

	A New Poland – Germany Double Tax Treaty Enters Into Force - Deloitte in Poland
		Under the currently binding Poland-Germany double tax treaty dividends are also subject to 5% or 15% withholding tax rates, however, the lower rate applies if the beneficial owner of the dividends holds directly at least 25% of the capital of the company paying of dividends.
		Currently binding double tax treaty does include similar provision and thus gains derived by a resident of Germany from the alienation of immovable property situated in Poland are treated like “other income”; and thus they are taxed exclusively in Germany.
		Furthermore, the New Treaty will introduce a rule that gains from the alienation of stock, shares and other rights in a company whose assets mainly, directly or indirectly, consist of immovable property located in a contracting state or of rights to such immovable property may be taxed in such state (Art.
	www.deloitte.com /dtt/alert/0,1001,sid=10604&cid=66672,00.html (679 words)

	How to Claim a Scholar Tax Treaty Benefit
		In most cases tax treaties benefit scholars by allowing them to exclude their entire income from teaching or research at a US university or similar institution for a period of two or three years.
		You are entitled to the benefit of the tax treaty between the US and the country that was your country of residence immediately prior to your arrival in the US In most cases this will also be your country of citizenship.
		If you are a resident for federal income tax purposes in 2004 you must file your tax return on Form 1040, 1040A or 1040EZ, but you must also file page 5 of Form 1040NR attached to your return to claim a tax treaty benefit in 2004.
	www.upenn.edu /oip/iss/tax/scholtre.html (1732 words)

	The New U.S.-U.K. Tax Treaty: Breaking New Ground for Cross-Border Pensions (Site not responding. Last check: 2007-10-29)
		The Treaty contains a number of provisions that affect individuals who spend part of their working lives in each of the two countries, and, in particular, the ability of such individuals to participate in pension plans established in the one or the other country, which will be the focus of this article.
		These changes are based in part on the U.S. Treasury Department's Model Income Tax Treaty of 1996 and are similar to provisions contained in the U.S. treaty with Ireland, signed in 1997, and the protocol to the U.S. treaty with the Netherlands, signed in March 2004, and not yet in effect.
		For treaty relief to be available in relation to contributions to a pension plan established in one of these countries, an application would need to be made to the U.S. competent authority (the Internal Revenue Service) for a determination that the pension plan generally corresponds to a plan in the United States.
	www.us.kpmg.com /microsite/tax/ies/tea/summer2004/stories/article01.htm (2183 words)

	Memo regarding U.S. - Swiss Tax Treaty
		Usually, the taxpayer is given a foreign tax credit for the taxes paid in connection with the first bite of the apple, so that the taxpayer ends up paying tax on the income as would have been imposed if the income were earned in the country of residency.
		Income will be taxed at the foreign partner’s U. tax rates (as either an individual or a corporation as the case may be), however, the income would not be taxed a second time, unless the member is a corporation and thus subject to the branch profits tax.
		Since the tax would be approximately equal, whether a corporate subsidiary or an LLC is used, the corporate subsidiary would provide more flexibility, and the tax on dividends would be postponed until an actual distribution is made.
	www.taxprophet.com /foreign/swiss_tax_memo.shtml (3886 words)

	Tax Executive, The: U.S. Model Income Tax Treaty
		In its July 28, 1992, comments on the proposed section 482 regulations, TEI recommended that the United States in its bilateral tax negotiations seek a provision requiring that the Competent Authorities submit to binding arbitration in the event they are unable to agree.
		TEI acknowledges that the need for limitations on treaty benefits in certain circumstances both to protect U.S. revenue and to encourage non-treaty partners to engage in treaty negotiations with the United States.
		Finally, we recommend that, in negotiating new treaties or protocols with existing treaty partners, entities and operations that are in existence as of the date of signing a treaty with a new treaty partner should be "grandfathered" for purposes of the ownership and base erosion tests.
	www.findarticles.com /p/articles/mi_m6552/is_n1_45/ai_13503360/pg_2 (1201 words)

	Treaties in Force - Status of International Tax Treaty Negotiations (Site not responding. Last check: 2007-10-29)
		The Tax Convention between Canada and the Republic of Bulgaria, as signed on March 3, 1999.
		The Canada-France Income Tax Convention, as signed on May 2, 1975 and amended by a Protocol signed on January 16, 1987 and a Protocol signed on November 30, 1995.
		The Canada-Japan Income Tax Convention, as signed on May 7, 1986; amended by a Protocol signed on February 19, 1999 and entered into force on December 14, 2000.
	www.fin.gc.ca /treaties/in_force-e.html (1433 words)

	Status of International Tax Treaty Negotiations (Site not responding. Last check: 2007-10-29)
		Tax Treaty Negotiations with the Republic of Korea (February 12, 2004).
		Tax Treaty Negotiations with Serbia and Montenegro (December 11, 2003).
		Tax Treaty Negotiations with Oman (December 11, 2002).
	www.fin.gc.ca /treaties/treatystatus_e.html (581 words)

	How to Claim a Student Tax Treaty Benefit
		This supplemental information sheet is for international students* who have already determined that they are entitled to the benefit of a tax treaty to reduce or eliminate their 2004 federal income taxes.
		To correctly claim most tax treaty benefits you must be certain of the type or types of income that you had in 2004.
		In most cases tax treaties benefit students by allowing them to exempt all of their non-service scholarship or fellowship income and a limited amount of their earned income from federal taxation.
	www.lehigh.edu /~intnl/tax/studenttaxtreaty.html (1514 words)

	Tax Treaty India
		If your child is also a non-resident for federal income tax purposes, which is usually true of a child in F-2 or J-2 status for example, you may not claim a personal exemption for the child.
		To claim the standard deduction on Form 1040NR write "Standard Deduction Allowed Under U.S.-India Tax Treaty" on line 3 of Schedule A (page 3) of Form 1040NR; place the appropriate amount for your filing status in the column to the right of line 3 and repeat on line 17.
		If you failed to claim the U.S. India tax treaty on your 2001, 2002 or 2003 federal income tax returns, or if you filed the wrong form for 2001, 2002, or 2003 you should file amended returns for these years.
	www.lehigh.edu /~intnl/tax/indiatre.html (689 words)

	Journal of Accountancy: Recent tax treaty developments (Site not responding. Last check: 2007-10-29)
		The branch tax was lowered from 10% to 5%.
		Reductions in the dividend withholding and branch tax rates now are subject to a phase-in of 7% from the effective date through the end of 1995, 6% in 1996 and 5% thereafter.
		Credit for U.S. estate tax is allowed against Canadian income tax on non-U.S. property in the case of the individual's death or against Canadian income tax imposed on U.S. source income in a given year.
	www.findarticles.com /p/articles/mi_m6280/is_n6_178/ai_15947689 (670 words)

	Opening Statement for Hearing on the Japan Tax Treaty and Sri Lanka Tax Protocol (Site not responding. Last check: 2007-10-29)
		In the case of taxes, we should work to ensure that companies pay their fair share, while not being unfairly taxed twice on the same revenue.
		Tax treaties are intended to prevent double taxation so that companies are not inhibited from doing business overseas.
		The original Japan Tax Treaty was signed in March 1971 and went into force in January 1973.
	lugar.senate.gov /pressapp/record.cfm?id=218367 (1124 words)

	Treasury Department Welcomes U.S.-Sri Lanka Tax Treaty - US Department of State
		A newly enacted tax treaty between the United States and Sri Lanka will serve to eliminate tax barriers to bilateral trade and help guard against the threat of double-taxation, according to a July 22 Treasury Department press release.
		With this entry into force, the provisions relating to withholding taxes will be effective for amounts paid or credited on or after September 1, 2004. The provisions relating to other taxes will be effective for taxable periods beginning on or after January 1, 2005.
		This agreement represents a new tax treaty relationship for the United States. The Treasury Department is committed to continuing to extend and broaden the U.S. tax treaty network, including new agreements with emerging economies.
	usinfo.state.gov /sa/Archive/2004/Jul/22-87126.html (313 words)

	Payroll Coordination and Tax Services - University of California Office of the President-Tax Treaty Information
		Student exemptions from withholding of income tax for personal services exist for several countries but are limited to specific dollar amounts per calendar year.
		Most treaties specify a limited number of years that an individual is eligible for the exemption.
		The IRS Publication 901- U.S. Tax Treaties (http://www.irs.ustreas.gov/pub/irs-pdf/p901.pdf) can be used for a quick reference guide for treaty information.
	www.ucop.edu /ucophome/cao/paycoord/taxcvr.html (372 words)

	FEDERAL TAX WITHHOLDING INSTRUCTIONS
		Eligibility for a Foreign National to use a tax treaty depends on the specific treaty between the U.S. and the home country, and the individual securing a social security number or Individual Taxpayer Identification Number (ITIN).
		Both immigration and tax laws place a number of restrictions on payments made to short-term foreign visitors, including those on B visas or visa waivers.
		The tax treaty exemption becomes effective for payments made after the treaty documents are processed by Payroll Services.
	www.fpd.finop.umn.edu /groups/ppd/documents/appendix/FedTax371.cfm (894 words)

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