U.S.–U.K. Tax Treaty (Model Tax Convention Example)
2001-07-24
2003-03-31
Summary
The United States has tax treaties with approximately 65 countries to prevent double taxation and fiscal evasion. These treaties generally reduce withholding taxes on dividends, interest, and royalties; establish rules for allocating taxing rights between countries; and provide mutual agreement procedures for resolving disputes. The U.S.–U.K. treaty is one of the most significant, given the volume of cross-border investment.
Parties
U.S. Implementing Legislation
Internal Revenue Code § 894 — Income Affected by Treaty
26 U.S.C. § 894
Provides that income of any kind shall be exempt from U.S. taxation to the extent required by any treaty obligation of the United States.
Internal Revenue Code § 7852(d) — Treaty Obligations
26 U.S.C. § 7852(d)
Establishes that no provision of the IRC shall apply if inconsistent with a treaty obligation, subject to the later-in-time rule.
Key Cases
Cook v. United States, 288 U.S. 102 (1933) — Later-in-time rule: a treaty prevails over an earlier statute and vice versa