Since 2003, dividends paid to individual shareholders from either a domestic corporation or a "qualified foreign corporation" are subject to tax at the reduced rates applicable to certain capital gains. A qualified foreign corporation includes certain foreign corporations that are eligible for benefits of a comprehensive income tax treaty with the United States. Notice 2011-64 provides the most recent list of the U.S. income tax treaties that meet the requirements under Code §1(h)(11).
The previous lists of the comprehensive income tax treaties were in Notices 2003-69 and 2006-101. The newest list in Notice 2011-64 adds Bulgaria and Malta.
Notice 2011-64 also specifies that for purposes of determining whether the limitation on benefits clause of the treaty is met, the foreign corporation must be "treated as though it were claiming treaty benefits, even if it does not derive income from sources within the United States."
The following is a list of the treaties from Notice 2011-64:
Trinidad and Tobago