The United States is a signatory to more than 60 income tax treaties with countries throughout the world.  Each treaty offers unique planning opportunities.  From permanent-establishment planning, subsidiary or branch formation, transfer-pricing considerations, anti-hybrid planning, and everything in between, our tax attorneys, CPAs, and experts provide insight and guidance that is custom-tailored to our clients and their unique circumstances.

International Tax Treaties

In addition to the U.S. and foreign statutory rules for the taxation of foreign income of U.S. persons and U.S. income of foreign persons, bilateral income tax treaties limit the amount of income tax that may be imposed by one treaty partner on residents of the other treaty partner. Treaties also contain provisions governing the creditability of taxes imposed by the treaty country in which income was earned in computing the amount of tax owed to the other country by its residents with respect to such income. Treaties further provide procedures under which inconsistent positions taken by the treaty countries with respect to a single item of income or deduction may be mutually resolved by the two countries.

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