Publication 901 - Introductory Material
New tax treaties and protocols. The United States has exchanged instruments of ratification for a new income tax treaty with Belgium and new protocols for
the income tax treaties
with Denmark, Finland, and Germany. The provisions of these treaties and protocols are included in the appropriate areas of
this publication. The
effective dates are as follows:
Belgium. The provisions relating to withholding tax at source are effective for amounts paid or credited on or after February 1, 2008.
For other taxes, the treaty is effective for tax periods beginning on or after January 1, 2008. A person entitled to benefits
under the previous
treaty can elect to have that treaty apply in its entirety for a twelve-month period following the date the new treaty would
otherwise apply.
Denmark. The provisions relating to withholding tax at source are effective for amounts paid or credited on or after February 1, 2008.
For other taxes, the protocol is effective for tax periods beginning on or after January 1, 2008.
Finland. The provisions relating to withholding tax at source are effective for amounts paid or credited on or after February 1, 2008.
However, the provisions for dividends exempt under Article 10(3) as amended by this protocol are effective January 1, 2007.
For other taxes, the
protocol is effective for tax years beginning on or after January 1, 2008.
Germany. The provisions relating to withholding tax at source are effective for amounts paid or credited on or after January 1, 2007.
For other taxes, the treaty is effective for tax years beginning on or after January 1, 2008. A person entitled to benefits
under the treaty before
modification by this protocol can elect to have the unmodified treaty apply in its entirety for a twelve-month period following
the date the protocol
would otherwise apply.
Disclosure of a treaty-based position that reduces your tax. If you take the position that any U.S. tax is overruled or otherwise reduced by a U.S. treaty (a treaty-based position), you
generally must
disclose that position on your affected return. See Application of Treaties, later.
U.S.-U.S.S.R. income tax treaty. The U.S.-U.S.S.R. income tax treaty remains in effect for the following members of the Commonwealth of Independent States:
Armenia,
Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan. That treaty will remain in effect
until new treaties with
these individual countries are negotiated and ratified. Provisions of the U.S.-U.S.S.R. income tax treaty are discussed in
this publication
under Commonwealth of Independent States.
U.S.-China income tax treaty. The U.S.-China income tax treaty does not apply to Hong Kong.
U.S.-United Kingdom income tax treaty. Generally, the treaty is effective for tax periods beginning on or after January 1, 2004. However, an individual who was otherwise
entitled to
treaty benefits under Article 21 (students and trainees) of the former treaty can continue to apply that provision.
U.S.-Japan income tax treaty. Generally, the treaty is effective for tax periods beginning on or after January 1, 2005. However, an individual who was entitled
to treaty
benefits under Article 19 (teachers and researchers) or Article 20 (students and trainees) of the former treaty as of March
30, 2004, can continue to
apply those provisions.
This publication will tell you whether a tax treaty between the United States and a particular country offers a reduced rate
of, or possibly a
complete exemption from, U.S. income tax for residents of that particular country.
Tables in the back of this publication show the countries that have income tax treaties with the United States, the tax rates
on different kinds of
income, and the kinds of income that are exempt from tax.
You should use this publication only for quick reference. It is not a complete guide to all provisions of every income tax
treaty.
Comments and suggestions.
We welcome your comments about this publication and your suggestions for future editions.
You can write to us at the following address:
Internal Revenue Service
Individual Forms and Publications Branch
SE:W:CAR:MP:T:I
1111 Constitution Ave. NW, IR-6526
Washington, DC 20224
We respond to many letters by telephone. Therefore, it would be helpful if you would include your daytime phone number,
including the area code, in
your correspondence.
You can email us at
*[email protected]. (The asterisk must be included in the
address.) Please put “
Publications Comment” on the subject line. Although we cannot respond individually to each email, we do appreciate your
feedback and will consider your comments as we revise our tax products.
Ordering forms and publications.
Visit
www.irs.gov/formspubs to download forms and publications, call 1-800-829-3676, or write to the address shown in the
How To Get Tax
Help section under
Mail.
Obtaining copies of treaties.
You can get complete information about treaty provisions from the taxing authority in the country from which you receive
income or from the treaty
itself.
You can obtain the text of most of the treaties at
www.irs.gov/businesses/international. You can also
obtain the text of most of the treaties at the following address:
Department of the Treasury
Office of Public Correspondence
1500 Pennsylvania Ave. NW — Rm. 3419
Washington, D.C. 20220
If you have specific questions about a treaty, you can get this information from most Internal Revenue Service offices
or from:
Internal Revenue Service
International Returns Section
P.O. Box 920
Bensalem, PA 19020-8518
Tax questions.
If you have a tax question, check the information available on
www.irs.gov or call 1-800-829-1040.
Useful Items - You may want to see:
Publication
-
519
U.S. Tax Guide for Aliens
-
597
Information on the United States-Canada Income Tax Treaty
-
686
Certification for Reduced Tax Rates in Tax Treaty Countries
See How To Get Tax Help near the end of this publication for information about getting these publications and forms.