" ... focuses on the treatment in U.S. income tax treaties of cross-border income derived by individuals for the performance of employment services, as directors' fees, in his or her capacity as an entertainer or sportsman, for the performance of government service or as a student or trainee, as well as payments received as a pension, social security payment, an annuity, alimony or child support. This Portfolio covers provisions in U.S. income tax treaties relating only to individuals and, where possible, the policy considerations that explain the variations from treaty to treaty. Particular attention is paid to widely-held notions of international tax fairness as reflected in U.S. model treaties and other model treaties, and to the provisions of the various bilateral income tax treaties to which the United States is a party. The ultimate goal of this Portfolio is to educate practitioners about the benefits available under provisions in U.S. income tax treaties that relate only to individuals, and the practical contexts in which they arise."
Published as: Tax Management portfolio 943, .
Formatted Contents Note
Detailed analysis. Introduction Residency, tie-breaker rules, and the saving clause Provisions relating only to individuals Summary and conclusion Working papers.
Digital File Characteristics
Source of Description
Description based on contents viewed on August 9, 2017; title from description page.
Available in Other Form
Print version: Williamson, R. Mark, 1960- U.S. income tax treaties. Arlington, VA : Tax Management Inc., -