Introduction to United States Income TAX Treaties

Dictated by:

Professor Dalton L. Dallazem

International Tax Professor and Advisor

Science Juris Doctor – SJD (UFPR – Brazil)

SJD Candidate – International Taxation – (UF – United States)

  • Start Date: 08/24/2020 - 13:00 UTC Time
  • End Date: 08/28/2020 - 15:00 UTC Time
  • Language: English
  • Price: 80 US Dollars
  • Total Course Time: 6 Hours
  • Includes a Digital Certificate from WORLDWIDE TAXNET LTD

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Full Program:

Session I

  • Overview of U.S. Tax Treaties – Structure and Sources of Income
  • Income Tax Treaties versus Internal Revenue Code – Treaty Override
  • Residence: - Citizenship - Substantial Presence and Tie-Breaker Rules - Saving Clause
  • Fixed, Determinable, Annual or Periodic Income – FDAP (Dividends, Interests and Royalties)

Session II

  • Business Income
  • Trade or Business and Permanent Establishment
  • Personal Services Income

Session III

  • Anti-treaty Shopping Provisions (Limitation on Benefits – LOB)
  • Relief from Double Taxation
  • 2017 Tax Reform and Dividends Received Deduction (DRD)

Recommended reading (not mandatory)

  • Avi-Yonah, Reuven S., International Tax as International Law (March 2004). U of Michigan Law, Public Law Research Paper No. 41; Michigan Law and Economics Research Paper No. 04-007. Available at SSRN: or
  • Kysar, Rebecca M., Unraveling the Tax Treaty (July 15, 2019). Minnesota Law Review, Forthcoming. Available at SSRN:
  • Filippo Alessandro Cimino – Associate Professor of Tax Law, Kore University of Enna (Italy)

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