Key provisions for 20 US tax treaties: dividend and interest withholding rates, pension article, tie-breaker, savings clause, and practitioner notes. US-Russia treaty suspended August 2023. Always verify against the current treaty text.
US-Russia Tax Treaty Suspended August 2023. Russia suspended the US-Russia income tax treaty (1992) effective August 8, 2023. Decree No. 585. No treaty benefits are available for Russian-source income. Standard withholding rates (30% on US-source income for NRAs, etc.) apply. FBAR and FATCA filing obligations for Russian accounts are not affected by the treaty suspension - they continue under domestic US law.
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Savings clause: Almost every US treaty contains a savings clause reserving the US right to tax its citizens and residents as if the treaty did not exist. This means US citizens and Green Card holders generally cannot use treaty provisions to avoid US tax - they can only use treaties to prevent double taxation (e.g., foreign tax credit). The savings clause exceptions (typically listed in a protocol) are narrow.
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Country
Status
Dividends (General)
Dividends (Qualified)
Interest
Royalties
Pension / Retirement
Tie-Breaker
Key Note
Sources: IRS Publication 901 (US Tax Treaties); full treaty texts at IRS.gov (US Income Tax Treaties A-Z); OECD Model Tax Convention. Rates reflect treaty provisions - actual withholding may differ based on beneficial ownership rules, limitation on benefits (LOB) clauses, and treaty eligibility requirements. Verify all positions against current treaty text before filing. Last reviewed: April 2026.
For informational purposes only. Treaty provisions summarized here are practitioner reference notes, not legal advice. Always verify against the current official treaty text at IRS.gov before taking any tax position. Treaty interpretation requires careful analysis of the specific article, protocol, and applicable domestic law. A tk.cpa resource. tk.cpa is - tk.cpa.
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