The Treasury Department and the Internal Revenue Service last Thursday issued guidance concerning the application of income tax treaties as they pertain to non-residents in service partnerships which are conducting activities in the United States.
“Revenue Ruling 2004-3 makes clear that a non-resident partner is subject to US income taxation on his share of income from the partnership to the extent that such income is attributable to the partnership’s activities in the United States, without regard to whether the partner performs services in the United States,” the Treasury announced in a statement.
It continued: “The guidance in this revenue ruling also applies in the case of other US income tax treaties that contain applicable provisions regarding independent personal services like the provisions in the US-Germany income tax treaty.”
The full text of the Revenue Ruling on the Application of Income Tax Treaties To Service Partnerships can be found in the Tax-News Resources section
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