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Internal Revenue Bulletin:  2015-18 

May 4, 2015 


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Notice 2015–35Notice 2015–35

Section 301 of James Zadroga 9/11 Health and Compensation Act of 2010, Public Law 111–347 (124 Stat. 3623) (the “Act”) added section 5000C to the Internal Revenue Code that imposes a 2 percent tax on payments made by the U.S. government to foreign persons pursuant to certain contracts. In addition, section 301(c) of the Act requires that section 5000C be applied in a manner consistent with the United States’ obligations under international agreements. Accordingly, section 5000C will not be applied if the payment is made to a foreign person entitled to relief from the tax imposed under section 5000C pursuant to an international agreement with the United States, including relief pursuant to a non-discrimination provision of a qualified income tax treaty when the foreign person is entitled to the benefit of that provision. Notice 2015–35 provides a current list of all "qualified income tax treaties" for purposes of section 5000C.

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