Income Tax Treaty Interpretation and Practice for Tax Professionals: Claiming and Reporting Tax Treaty Positions for Individuals
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers, professionals and preparers with a solid overview and explanation of key income tax treaty provisions needed to determine whether their individual clients may take treaty-based return positions. The speakers will enable advisers and preparers to complete IRS Form 8833 Treaty-Based Return Position Disclosure, IRS Form 8802 Application for U.S. Residency Certification and Form W-8BEN Certificate of Foreign Status and Beneficial Owner.
Outline
- Basic structure of income tax treaties
- Common features of tax treaties
- Persons who can benefit from an income tax treaty
- Application of the “savings clause” to U.S. citizens
- Personal services income
- Interest and dividends
- Compliance and forms
Benefits
The panel will discuss these and other critical issues:
- Purposes of income tax treaties
- Persons who can claim benefits
- Common residency provisions, and tie breakers for dual residents
- Savings clauses applicable to U.S. citizens
- Exemptions for personal services income
- Treatment of interest and dividends
- How to complete Forms 8833, 8802 and W-8BEN with examples
Faculty

Alison N. Dougherty, J.D., LL.M.
Senior Tax Manager
Aronson
Ms. Dougherty specializes in corporate tax, partnership tax, international tax and real estate tax. She has expertise... | Read More
Ms. Dougherty specializes in corporate tax, partnership tax, international tax and real estate tax. She has expertise in international tax compliance with preparation and review of Forms 8865, 5471, 5472, 1120F, 8832, 1042, 1042S, 8804, 8805, 8813, 926, 1118, 1116, 5713, 3520, 3520A W-8, 8833 and FBAR. She also works with business and individual clients on a broad range of tax structuring, planning and controversy engagements.
Close
William K. Norman, J.D., LL.M. (Taxation)
Partner
Ord & Norman
Mr. Norman practices as a tax lawyer. He limits his practice to international tax planning and compliance for high net... | Read More
Mr. Norman practices as a tax lawyer. He limits his practice to international tax planning and compliance for high net worth individuals, corporations and joint ventures. He regularly works with U.S. businesses expanding overseas, foreign based businesses establishing operations in the United States, and multinational families on wealth transfer matters. He assists in-house staff of businesses and their outside tax professionals with filings, audits and appeals involving international tax issues and represents individuals in Overseas Delinquent Filings, Voluntary Disclosures and Streamlined Filing Procedures.
Close