Question:

"The Role of Treaties on International Tax Transactions" Please respond to the following:

Go to the Internal Revenue Service (IRS) Website, located at http://www.irs.gov/Individuals/International-Taxpayers/The-U.S.-Model-Income-Tax-Convention-and-Model-Technical-Explanation. Locate the "U.S. Model Income Tax Convention" used to negotiate treaties with other nations and review

Article 5: Permanent Establishment, Article 7: Business Profits, and Article 22: Limitation on Benefits in the model. Next, examine how current U.S. multinational corporations can use provisions of treaties to lower taxes.

Speculate how the Internal Revenue Service (IRS) can apply Article 22: Limitation on Benefits to reduce abuse of current treaty provisions. Provide examples to support your response.

Imagine you are a CPA representing clients with investments in foreign financial institutions and non-financial foreign entities. Provide your client with at least two (2) ways to avoid penalties under the Foreign Account Tax Compliance Act (FATCA)