International Tax

U.S. Income Tax Treaties — Provisions Relating Only to Individuals (Portfolio 6870)

  • This Portfolio focuses on the treatment in U.S. income tax treaties of income derived by an individual in his or her capacity as an independent worker or employee, government worker, director.


Bloomberg Tax Portfolio, U.S. Income Tax Treaties – The Limitation on Benefits Article, discusses in detail the limitation on benefits (LOB) article of U.S. income tax treaties.

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.

With respect to estate and gift tax treaties, see 837 T.M., Non-Citizens — Estate, Gift and Generation-Skipping Taxation (Estates, Gifts, & Trusts Series), and 6896 T.M., U.S. Estate and Gift Tax Treaties.

This Portfolio may be cited as Williamson, 6870 T.M., U.S. Income Tax Treaties — Provisions Relating Only to Individuals.

Table of Contents

I. Introduction
II. Residency, Tie-Breaker Rules, and the Saving Clause
III. Provisions Relating Only to Individuals
IV. Summary and Conclusion

R. Mark Williamson
Alston & Bird LLP
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