Table of Contents
New tax treaty and protocol. The United States has exchanged instruments of ratification for a new income tax treaty with Malta and a new protocol amending the income tax treaty with New Zealand. The effective dates for both are as follows.
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The provisions for withholding tax at source are effective for amounts paid or credited on or after January 1, 2011.
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The provisions for other taxes, are generally effective for tax periods beginning on or after January 1, 2011.
Table 1. The columns for royalty income (Income Codes 10–12) have been expanded. Industrial Royalties (Income Code 10) has been divided into two categories (equipment and know-how) and Copyright Royalties (Income Code 12) has been divided into two categories (copyrights and patents). None of the rates have changed; rather, rates previously explained in footnotes for these categories are now shown in a separate column. Also, the columns for Capital Gains (Income Code 9) and Real Property Income and Natural Resource Royalties (Income Code 13) are no longer shown.
Disclosure of a treaty-based position that reduces your tax. If you take the position that any U.S. tax is overruled or otherwise reduced by a U.S. treaty (a treaty-based position), you generally must disclose that position on your affected return. See Application of Treaties, later.
U.S.–U.S.S.R. income tax treaty. The U.S.–U.S.S.R. income tax treaty remains in effect for the following members of the Commonwealth of Independent States: Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan. That treaty will remain in effect until new treaties with these individual countries are negotiated and ratified. Provisions of the U.S.–U.S.S.R. income tax treaty are discussed in this publication under Commonwealth of Independent States.
U.S.–China income tax treaty. The U.S.–China income tax treaty does not apply to Hong Kong.
U.S.–Italy income tax treaty. The U.S.–Italy income tax treaty was generally effective on January 1, 2010. A person entitled to benefits under the former treaty could elect to have that treaty apply in its entirety for a twelve-month period following the date the new treaty would otherwise apply. If you need information on the former treaty, see Publication 901 (Rev. April 2010).
This publication will tell you whether a tax treaty between the United States and a particular country offers a reduced rate of, or possibly a complete exemption from, U.S. income tax for residents of that particular country.
Tables in the back of this publication show the countries that have income tax treaties with the United States, the tax rates on different kinds of income, and the kinds of income that are exempt from tax.

Internal Revenue Service
Individual Forms and Publications Branch
SE:W:CAR:MP:T:I
1111 Constitution Ave. NW, IR-6526
Washington, DC 20224
Internal Revenue Service
1201 N. Mitsubishi Motorway
Bloomington, IL 61705-6613
Department of the Treasury
Office of Public Correspondence
1500 Pennsylvania Ave. NW — Rm. 3419
Washington, D.C. 20220
Internal Revenue Service
International Section
Philadelphia, PA 19255-0725
Publication
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519 U.S. Tax Guide for Aliens
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597 Information on the United States–Canada Income Tax Treaty
Form (and Instructions)
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8833 Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b)
See How To Get Tax Help near the end of this publication for information about getting these publications and forms.
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