The U.S. IRS has released an international practice unit on the Shipping and Air Transport Article, which provides an overview of the article as it commonly applies in U.S. income tax treaties. Due to the defined scope of the Shipping and Air Transport article’s application and practical experience related to U.S. taxation of income covered by this article, the practice unit generally focuses on corporate taxpayers. The practice unit notes that not all U.S. income tax treaties have a Shipping and Air Transport article; however, in most of these cases, a separate agreement exists between the United States and the...