International Tax

U.S. Income Tax Treaties — Income Not Attributable to a Permanent Establishment (Portfolio 938)

  • This Portfolio discusses aspects of U.S. income tax treaties that relate to income that is not attributable to a permanent establishment.

Description

Bloomberg Tax Portfolio, U.S. Income Tax Treaties – Income Not Attributable to a Permanent Establishment, No. 938, discusses aspects of U.S. income tax treaties that relate to income that is not attributable to a permanent establishment. The Portfolio covers general U.S. tax treaty considerations, including background regarding the impact of tax treaties on the taxation of foreign persons, the relationship of tax treaty provisions to U.S. tax law, the conditions for obtaining treaty benefits, and certain anti-abuse rules embedded within U.S. income tax treaties and within U.S. tax law. Specific treaty articles that address specific types of income, including those on dividends, interest, royalties, capital gain, income from real property, and other income are described in detail. The Portfolio includes a summary of certain relevant documentation and reporting requirements.

This Portfolio may be cited as Nauheim and Scott, 938 T.M., U.S. Income Tax Treaties – Income Not Attributable to a Permanent Establishment.

Table of Contents

I. General Overview Regarding Bilateral U.S. Income Tax Treaties
II. Conditions for Treaty Benefits
III. Anti-Abuse Rules
IV. Dividends
V. Interest
VI. Royalties
VII. Real Property Income
VIII. Capital Gains
IX. Other Income
X. Documentation and Reporting

nauheim_stephen_2015
Stephen Nauheim
PricewaterhouseCoopers LLP
Eileen Scott
Director
PricewaterhouseCoopers LLP
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