U.S. income tax treaties : benefits provided by a country to its own residents and citizens / by Karl L. Kellar, Jones Day and Patrick J. Browne Jr., KPMG LLP.

Arlington, VA : Tax Management Inc., [2014]-

1 online resource.

Updated irregularly

Tax management portfolios ; 6875-2nd.

"This Portfolio, 6875-2nd T.M., U.S. Income Tax Treaties--Benefits Provided by a Country to Its Own Residents and Citizens, covers the benefits granted under a bilateral income tax treaty by one of the parties to the treaty to its own residents. Among these benefits are (i) elimination or reduction of the tax liability of a country's residents in order to provide relief from double taxation that would otherwise arise from the other country's imposition of tax on the same items of income, with a focus on treaty and Code re-sourcing provisions; (ii) elimination or reduction of the tax liability of a country's residents with respect to specific types of income for which the treaty assigns primary taxing jurisdiction to the other country (e.g., compensation for government employment, benefits from and contributions to pensions and retirement plans, and alimony and child support); (iii) the saving clause, which preserves the right of the United States (and often the foreign country) to tax its citizens on worldwide income even though they might otherwise qualify for treaty benefits with respect to such income (e.g., if a U.S. citizen is a resident of a foreign treaty partner); (iv) the non-discrimination clause, under which contracting states cannot discriminate against each other's nationals or residents in matters of taxation; and (v) a brief discussion of the mutual agreement (competent authority) procedure, under which a resident of either country may invoke a procedure for bilateral negotiations to relieve double taxation not otherwise resolved by the treaty's provisions."

Description based on contents viewed on August 16, 2019; title from description page.

www

Print version: Kellar, Karl L. U.S. income tax treaties. Arlington, VA : Tax Management Inc., [2019]-

BNA Premier package.

English

Monographs & Serials
Electronic Resources