Tax Treaties part 3
Channel: International Tax
Date: 2018-01-22

Learn about limits on treaty benefits and required reporting of tax reductions due to treaties.
Time   Topic
00:00  Lead-in
00:11  Treaty shopping:  fun & legal
00:53  Limits on application of treaties
02:18  Example
02:40  Key aspects of Limitation on Benefits articles of treaties
03:38  Base erosion
05:23  Reporting treaty-based return positions
06:52  Example:  salesman doing business but not PE
08:37  Penalty for not filing Form 8833
10:26  Closing

There is no quiz for this part.

Resources:
Law:  26 USC 894  http://uscode.house.gov/view.xhtml?req=(title:26%20section:894%20edition:prelim)%20OR%20(granuleid:USC-prelim-title26-section894)&f=treesort&edition=prelim&num=0&jumpTo=true

Treaties:  IRS website:  https://www.irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z

Form 8833:  https://www.irs.gov/pub/irs-pdf/f8833.pdf

For advice, see http://sfoxcpa.com