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U.S. IRS Releases Practice Units on Determining an Individual’s Residency for Treaty Purposes

14 September 2018

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Approved Changes

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United States

The U.S. IRS has released international practice unit on Determining an Individual’s Residency for Treaty Purposes. --- A country’s domestic law provides specific rules for the taxation of income of individuals that are residents or nonresidents of that country as defined under domestic law. The United States’ domestic tax law is embodied by the Internal Revenue Code (the "Code" or "IRC"), Treasury regulations, and applicable rulings and case law. A country may, however, enter into a bilateral income tax agreement (a "treaty" or "tax treaty") with another country to modify the results that might otherwise occur under the countries’ domestic...