For Tax Professionals  
T.D. 8722 October 21, 1997

Guidance Regarding Claims for Certain
Income Tax Convention Benefits

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 8722] RIN 1545-AV33

TITLE: Guidance Regarding Claims for Certain Income Tax Convention Benefits

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Temporary regulations.

SUMMARY: This document contains temporary regulations relating to eligibility for benefits under income tax treaties for payments to entities. The regulations set forth rules for determining whether U.S. source payments made to entities, including entities that are fiscally transparent in the United States and/or the applicable treaty jurisdiction, are eligible for treaty-reduced tax rates. The regulations affect the determination of tax treaty benefits with respect to U.S. source income of foreign persons. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.

DATES: These regulations are effective July 2, 1997. These regulations apply to amounts paid on or after January 1, 1998.

FOR FURTHER INFORMATION CONTACT: Elizabeth Karzon, (202) 622-3860 (not a toll-free number).

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