894 Treaties

September 23, 2022

How inaccurate is the IRS Version of the Sweden Treaty (pretty inaccurate)

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Posted on September 23, 2022 in 894 Treaties |

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December 15, 2021

Five New IRS Practice Units

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Posted on December 15, 2021 in 453 Installment Sales, 59A BEAT, 701 Partnerships, 894 Treaties, 901 Foreign Tax Credits |

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June 08, 2021

130 New Tax Charts – LOB Active Trade or Business Test – Derived In Connection With

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Posted on June 08, 2021 in 894 Treaties, Charts - Situational Charts |

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November 08, 2020

U.K. Pension Lump-Sum Distributions

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Posted on November 08, 2020 in 894 Treaties, Country - UK |

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March 18, 2019

New IRS Practice Units published in March

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Posted on March 18, 2019 in 894 Competent Authority, 894 Treaties, Other - IRS Practice Units |

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January 31, 2019

New IRS Practice Unit: Creation of a Permanent Establishment (PE) through the Activities of a Dependent Agent in the United States

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Posted on January 31, 2019 in 894 Permanent Establishment, 894 Treaties, Other - IRS Practice Units |

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November 13, 2018

Updated IRS Practice Units by Topic Page

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Posted on November 13, 2018 in 367(b) Fgn to Fgn Corp, 367(d), 482 Cost Sharing Arrangements, 6038A 5472s, 6048 Foreign Trusts, 641-684 Trusts, 7701(b) Individual Residency, 861 Source of Income, 884 Branch Profits Tax, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 951 Subpart F Income, 956 Investments in U.S. Property, 987 Branch Transactions, 988 Transactions, Other - IRS Practice Units |

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September 14, 2017

Withdrawal of Prior Blog Post Regarding Australian Superannuation Funds

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Posted on September 14, 2017 in 402(b) Foreign Pensions, 894 Treaties |

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August 04, 2017

Belize IBC Selling Through Amazon FBA

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Posted on August 04, 2017 in 861 Source of Income, 864 Engaged in U.S. Trade or Business (ETOB), 894 Treaties |

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August 05, 2016

IRS International Practice Units By Category

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Posted on August 05, 2016 in 1441 U.S. Withholding Taxes, 163(j) Earnings Stripping, 367(b) Fgn to Fgn Corp, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 6048 Foreign Trusts, 7701(b) Individual Residency, 861 Source of Income, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 911 Housing Cost Amounts, 951 Subpart F Income, 956 Investments in U.S. Property, 988 Transactions, 989 Qualified Business Unit (QBU), Other - IRS Practice Units |

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May 10, 2016

Tax Treaty Limitation on Benefits (“LOB”) & Form W8-BEN-E

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Posted on May 10, 2016 in 894 Limitation on Benefits, 894 Treaties, Form W-8 BEN / BEN-E |

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September 22, 2014

International PLRs of Note for the 38th week of 2014

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Posted on September 22, 2014 in 894 Treaties, 901 Foreign Tax Credits, Authority - PLRs / CCAs |

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November 02, 2013

International PLRs for the 43rd week of 2013

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Posted on November 02, 2013 in 1(h)(11) Qualified Dividend Income, 701 Partnerships, 861 Source of Income, 894 Limitation on Benefits, 894 Treaties, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891 |

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November 24, 2012

International PLRs of the 47th week of 2012

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Posted on November 24, 2012 in 1291 PFICs, 7701-3 Check-the-Box Elections, 894 Treaties, Authority - PLRs / CCAs, Form 8832 |

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September 02, 2012

Canada & U.S. to Apply the Authorized OECD Approach (“AOA”) for Attribution of Business Profits

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Posted on September 02, 2012 in 894 Competent Authority, 894 Permanent Establishment, 894 Treaties, Country - Canada |

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August 31, 2012

Belgian Municipal and Conurbation Income Taxes are Covered by the Treaty

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Posted on August 31, 2012 in 894 Competent Authority, 894 Treaties |

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August 24, 2012

International PLRs & CCA of the 31st week of 2012

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Posted on August 24, 2012 in 402(b) Foreign Pensions, 7701-3 Check-the-Box Elections, 894 Treaties, 911 Foreign Earned Income Exclusion, Authority - PLRs / CCAs, Form 2555, Form 8832 |

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May 14, 2012

International PLRs of the 19th week of 2012

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Posted on May 14, 2012 in 7701-3 Check-the-Box Elections, 894 Treaties, 953(d) Dom. Election for Fgn. Ins. Co., Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891 |

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April 01, 2012

International PLRs of the 13th week of 2012

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Posted on April 01, 2012 in 7701-3 Check-the-Box Elections, 894 Treaties, Authority - PLRs / CCAs, Form 8832, Form 8891 |

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March 29, 2012

International PLRs of the 12th week of 2012

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Posted on March 29, 2012 in 7701(b) Individual Residency, 894 Treaties, Authority - PLRs / CCAs, Other - Other |

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March 16, 2012

International PLRs of the 10th week of 2012

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Posted on March 16, 2012 in 1291 PFICs, 894 Treaties, Authority - PLRs / CCAs, Form 1042, Form 8891 |

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January 22, 2012

Income Accruing in Foreign Retirement Plans

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Posted on January 22, 2012 in 402(b) Foreign Pensions, 6048 Foreign Trusts, 894 Treaties, Form 3520 / 3520-A, Form 8938, Other - FBAR, Other - Other |

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October 18, 2010

OECD Commentary on Electronic Commerce for Permanent Establishments

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Posted on October 18, 2010 in 894 Treaties |

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June 03, 2010

U.S. Model Treaty: Limitation on Benefits Flowchart

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Posted on June 03, 2010 in 894 Treaties, Charts - Flowcharts |

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May 18, 2010

Pensions Under the Belgium-U.S. Income Tax Treaty

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Posted on May 18, 2010 in 402(b) Foreign Pensions, 894 Treaties |

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