Tax Treaties, Part 1
Channel: International Tax
Date: 2017-12-12

Learn the basics of U.S. income tax treaties in this 3 part playlist. This one covers common provisions and resident (eligible for the treaty) defined.  Here's what you will see:
00:00  Introduction
01:44  Common provisions
02:54  Resident defined (basic)
03:47  Business profits & PE (basic; see Part 2)
04:41  Reduce withholding taxes
05:39  Grant foreign tax credit
06:09  Resident defined (details)
07:47  Quiz and closing

Resources:
IRS Publication 901, U.S. Tax Treaties  https://www.irs.gov/pub/irs-pdf/p901.pdf
IRS Tax Treaties A to Z  https://www.irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z

Quiz:
1.  Which of the following are in nearly all U.S. income tax treaties?  Check all that apply. 
Definition of resident
  a. Reduced tax rate on business income
  b. Reduced tax rate on interest
  c. Specify what taxes are covered
2.  True or false:  Nearly all U.S. tax treaties are the same as the U.S. model treaty. 
True
False
3.  If an individual is resident in two treaty countries, what usually happens? 
  a. He/she gets taxed in both countries.
  b. He/she has to apply to each country for partial reduction of tax.
  c. A tie breaker rule determines which country gets to tax him/her.
4.  Where is a corporation resident under most treaties? 
  a. Where it is incorporated or controlled
  b. Where it has most of its business
  c. Where it holds annual shareholder meetings


Alternative resources:
OECD Model Tax Treaty
  and explanation of same

Quiz answers:  1.c., 2.false, 3.c., 4.a.