Form 8833 (Rev. December 2000)

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8833
Treaty-Based Return Position Disclosure
Form
Under Section 6114 or 7701(b)
OMB No. 1545-1354
(Rev. December 2000)
Department of the Treasury
Attach to your tax return.
Internal Revenue Service
Attach a separate Form 8833 for each treaty-based return position taken. Failure to disclose a treaty-based return position may
result in a penalty of $1,000 ($10,000 in the case of a C corporation) (see section 6712).
Name
U.S. taxpayer identifying number
Address in country of residence
Address in the United States
Check one or both of the following boxes as applicable:
● The taxpayer is disclosing a treaty-based return position as required by section 6114
● The taxpayer is a dual-resident taxpayer and is disclosing a treaty-based return position as required by
Regulations section 301.7701(b)-7
Check this box if the taxpayer is a U.S. citizen or resident or is incorporated in the United States
1
Enter the specific treaty position relied on:
3
Name, identifying number (if available to the taxpayer), and
address in the United States of the payor of the income (if
a
Treaty country
fixed or determinable annual or periodical). See instructions.
b
Article(s)
2
List the Internal Revenue Code provision(s) overruled or
modified by the treaty-based return position
4
List the provision(s) of the limitation on benefits article (if any) in the treaty that the taxpayer relies on to prevent application
of that article
5
Explain the treaty-based return position taken. Include a brief summary of the facts on which it is based. Also, list the nature
and amount (or a reasonable estimate) of gross receipts, each separate gross payment, each separate gross income item,
or other item (as applicable) for which the treaty benefit is claimed
8833
For Paperwork Reduction Act Notice, see back of form.
Cat. No. 14895L
Form
(Rev. 12-2000)

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