Articles Common to U.S. Income Tax Treaties

Who May Claim Treaty Benefits?

Residence

Limitation on Benefits

Doing Business in a Contracting State

Permanent Establishment

Business Profits

Branch Profits Tax

Income from Real Property

Relief from Double Taxation

Passive Income Sourced to a Contracting State

Dividends

Interest

Royalties

Capital Gains from Personal Property

Income Attributable to Personal Services

Independent Personal Services

Dependent Personal Services

Artistes and Athletes

Pensions

Government Service

Students and Trainees

Transfer Pricing, Controversy Resolution and Exchange of Information

Associated Enterprises

Mutual Agreement Procedure

Information Exchange and Administrative Assistance

Nondiscrimination

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