The APA Program provides an alternative dispute resolution mechanism for taxpayers and the IRS to resolve complex international transfer pricing cases.
If you are a U.S. citizen or resident, you can request assistance from the U.S. competent authority if you think that the actions of the United States, a treaty country, or both, cause or will cause a tax situation not intended by the treaty between the two countries.
The income sourcing rules determine which income is taxable to a foreign person and which income qualifies for the foreign tax credit and the earned income exclusion of US persons.
Provides a list of countries that have submitted KYC rules and whether those rules have been approved. It also provides links to Country Specific Attachments.
Tax treaties may allow residents of foreign countries to be taxed at a reduced rate, or be exempt from U.S. income taxes on certain items of income they receive from sources within the United States.