author_orbitax
Orbitax

Share This Article

U.S. IRS Releases Practice Unit on MAP Under U.S. Income Tax Treaties

11 March 2019

|

Approved Changes

|

United States

The U.S. IRS has released an international practice unit on the Competent Authority Process Under a MAP Article of a U.S. Income Tax Treaty. --- One purpose of U.S. income tax treaties is to reduce or eliminate double taxation on income from sources within one Contracting State (either the United States or the other country party to the particular treaty) paid to a resident of the other Contracting State. The competent authority process provides broad access to a mechanism under the Mutual Agreement Procedure (MAP) article of a U.S. income tax treaty to alleviate double taxation (and other taxation not...