U.S. Tax Treaties: Planning, Application, and Compliance

Author: Robert J. Misey

Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2028 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card

U.S. tax treaties contain vital information for businesses as they provide an "alternative" version of tax law that often supersedes the Internal Revenue Code in international transactions. Properly advise your management team or clients on how to plan for tax savings and avoid key compliance problems by gaining a complete understanding of how the key provisions contained in most U.S. tax treaties can affect their business. Robert Misey, who has authored the treatise A Practical Guide to U.S. Taxation of International Transactions, will conclude the program with preparing a sample Form 8833 to obtain treaty benefits.

Publication Date: September 2025

Designed For
Tax accountants, tax lawyers, and tax professionals in industry.

Topics Covered

• Introduction to Treaties
• Residencey
• Permanent Establishments
• Withholding Rates
• Limitation on Benefits
• Other Provisions
• Compliance
• Planning

Learning Objectives

• Explain the recent development of new treaties and repeal of old treaties
• Describe the purpose of income tax treaties in the tax regimes of countries
• Identify common provisions in the U.S. Model Treaty
• Describe the "tie-breaker" rule when a person qualifies as a resident in more than one country
• Explain how to prepare Form 8833 for a taxpayer claiming the benefits of a treaty that conflicts with the Internal Revenue Code

Level
Basic

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None