Table of Contents
New tax treaties and protocol. The United States has exchanged instruments of ratification for new income tax treaties with Bulgaria and Iceland and a new protocol to the income tax treaty with Canada. The provisions of these treaties and protocol are included in the appropriate areas of this publication. The effective dates are as follows: Bulgaria. The provisions for withholding tax at source are effective for amounts paid or credited on or after January 1, 2009. For other taxes, the treaty is effective for tax periods beginning on or after January 1, 2009. Canada. The provisions for withholding tax at source are generally effective for amounts paid or credited on or after February 1, 2009. For other taxes, the protocol is generally effective for tax years beginning on or after January 1, 2009. Certain provisions, none of which are discussed in this publication, have different effective dates.Publication 597, Information on the United States—Canada Income Tax Treaty (Rev. April 2009), provides a more detailed explanation of the treaty as amended by the protocol. Iceland. The provisions for withholding tax at source are effective for amounts derived on or after January 1, 2009. For other taxes, the new treaty is effective for tax years beginning on or after January 1, 2009. An individual who was otherwise entitled to treaty benefits under Article 21 (Teachers) of the former treaty can continue to apply those provisions. A person entitled to benefits under the former 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.
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.
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.
Internal Revenue Service
Individual Forms and Publications Branch
SE:W:CAR:MP:T:I
1111 Constitution Ave. NW, IR-6526
Washington, DC 20224
Department of the Treasury
Office of Public Correspondence
1500 Pennsylvania Ave. NW — Rm. 3419
Washington, D.C. 20220
Internal Revenue Service
International Returns Section
P.O. Box 920
Bensalem, PA 19020-8518
Publication
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519 U.S. Tax Guide for Aliens
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597 Information on the United States–Canada Income Tax Treaty
Form (and Instructions)
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8833 Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b)
See How To Get Tax Help near the end of this publication for information about getting these publications and forms.
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