U.S. Income Tax Treaties — Benefits Provided by a Country to Its Own Residents and Citizens (Portfolio 6875)

Description

Bloomberg Tax Portfolio, 6875 T.M., U.S. Income Tax Treaties — Benefits Provided by a Country to Its Own Residents and Citizens, covers the benefits granted under a bilateral income tax treaty by one of the parties to the treaty to its own residents and citizens. Among these benefits are: (1) elimination or reduction of the tax liabilities of a country’s residents and citizens in order to provide relief from double taxation that would otherwise arise from the other country’s imposition of tax on the same items of income, with a focus on treaty and Code resourcing provisions; (2) elimination or reduction of the tax liabilities of a country’s residents and citizens with respect to specific types of income for which the treaty assigns primary taxing jurisdiction to the other country (e.g., compensation for government employment, benefits from and contributions to pensions and retirement plans, and alimony and child support); (3) correlative adjustments in the case of transfer pricing adjustments involving associated enterprises; (4) the Mutual Agreement Procedure, under which a person may invoke a procedure for bilateral negotiations to relieve double taxation not otherwise resolved by the treaty’s provisions; and (5) non-discrimination, under which Contracting States cannot discriminate against each other’s nationals or residents in matters of taxation.

This Portfolio may be cited as Kellar and Browne Jr., 6875 T.M., U.S. Income Tax Treaties — Benefits Provided by a Country to Its Own Residents and Citizens.

Table of Contents

I. Introduction
II. The Saving Clause
III. Relief from Double Taxation
IV. Residence Country Benefits for Employees of the Other Contracting State
V. Other Residence Country Benefits Specifically for Individuals
VI. Associated Enterprises
VII. Mutual Agreement Procedure
VIII. Non-Discrimination