Federal Tax Law Research: Locating Tax Treaties

Locating Tax Treaties

Information Provided By The Internal Revenue Service (IRS):

The IRS publishes Publication 901, U.S. Tax Treaties, which discusses whether tax treaties between the United States and particular countries offer a reduced rate of or exemption from U.S. income tax for residents of those countries. Publication 901 is available at the following site: http://www.irs.ustreas.gov/publications/p901/index.html or in pdf form at: http://www.irs.gov/pu b/irs-pdf/p901.pdf.

The IRS also provides links to the text of most of the income tax treaties and the Department of the Treasury's technical explanations of them at: http://www.irs.gov/business es/international/article/0,,id=96739,00.html.

Other Sources for Treaties:

For very up to date information on recently issued tax treaties, check Wor ldwide Tax Daily, previously known as Tax Notes International, available at the Harvard Law School Library, ILS K 4471.2 .T395, or on Lexis in the FEDTAX;TNI database. Worldwide Tax Daily contains the full text of recently enacted international tax documents and treaties organized by individual countries.

International Tax Treaties of All Nations: Containing English Language Texts of All Tax Treaties Between Two or More Nations, ILS RR K 4473.A1 I56. This source is kept up-to-date with supplements and contains an index.

RIA’s United States Tax Reporter Volume 20, KF 6285.P742x. Volume 20 contains the text of United States income and estate and gift tax treaties along with explanatory material. This volume is updated weekly. This information is also available online in RIA Checkpoint accessible through the Harvard Law School Network, and available in some law firms. In RIA Checkpoint click in the box in front of "U.S. Tax Treaties in Force" under the Primary Source Materials heading, enter search terms in the box at the top of the screen and click on search.

CCH’s Tax Treaties, ILS RR KF 6306.U54x. This looseleaf service provides the text of United States income and estate and gift tax treaties along with explanatory material and annotations. It also includes Cumulative Bulletin citations for each treaty. These volumes are updated monthly. Treaty information is also available online in CCH Tax Research NetWork accessible through the Harvard Law School Network and available at some law firms. In CCH Tax Research NetWork, in the Federal Tab, click on the boxes in front of Tax Treaties Reporter under the "CCH Explanations and Analysis" heading and in front of the "Legislative Documents, Treaties" file under the Primary Sources heading, enter search terms in the box at the top of the screen and click on search.

Westlaw:
· FTX-TREATIES This Federal Taxation—US Treaties and Conventions database contains tax treaties issued by the Internal Revenue Service since 1955.
· WGL-TREATIES This database contains Andersen’s Analysis of United States Income Tax Treaties. This treatise provides guidance on how United States tax treaties affect international business transactions. It is organized by type of income or economic activity and discusses how the income of various types of taxpayers is treated under a specific treaty, as well as the principles that United States authorities use to interpret and apply the treaty.

Lexis:
· FEDTAX;TNI Tax Analyst's Worldwide Tax Daily
· INTLAW;ILMTY This database contains treaties published in International Legal Materials from 1975 to the present.
· INTLAW;INTTXT This database, Rhoades & Langer U.S. International Taxation & Tax Treaties, contains annotated texts of all United States income tax treaties with in-depth analysis of the treaties. This work is also available in print: ILS RR KF6306 .R48