TAX 9869 Lecture Notes - Lecture 57: Pension Fund, Model Treaty, Tax Treaty
Document Summary
Foreign pship and have multiple foreign investments that can all be pfics. So when fp gives you a k-1 equivalent or k-1 and ur a us guy that owns 1% It should give you info about ach pfic and say here"s what u need 2 make an election. Designed to reduce or eliminate double taxation. Has weight within the law as a treaty. Whenever conflict in law: rule is always look to last in time (later in time enacted follow that) You can have sec. of irc from 1986 or 2010 and have inc tax treaty ratified in 2018 and bc its later in time u would follow that over the tax provision/law bc treaty = law. Special arm of govt that will go negotiate inc tax treaty w/ diff countries. But the senate has to approve it//ratify it and pres. signs it. Should not be confused w/ other types of treaties:
