U.S. Income Tax Treaties Fundamentals

Summary

This practice note discusses how tax treaties operate in transactions between U.S. and non-U.S. parties (also referred to as cross-border transactions). If you are advising clients on transactions involving non-U.S. jurisdictions, you should understand how tax treaties operate in order to successfully advise a client on how to minimize taxes in the relevant countries. Tax treaties apply to both individuals and corporations and cover federal income and excise taxes. Tax treaties do not cover social security or state and local taxes. This practice note will focus on the U.S. federal income tax implications of cross-border transactions utilizing a tax treaty.