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2010 Taxes

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2010 Taxes

2010 taxes 1. 2010 taxes   Organizations Subject to the Tax Table of Contents The tax on unrelated business income applies to most organizations exempt from tax under section 501(a). 2010 taxes These organizations include charitable, religious, scientific, and other organizations described in section 501(c), as well as employees' trusts forming part of pension, profit-sharing, and stock bonus plans described in section 401(a). 2010 taxes In addition, the following are subject to the tax on unrelated business income. 2010 taxes Individual retirement arrangements (IRAs), including traditional IRAs, Roth IRAs, Coverdell IRAs, simplified employee pensions (SEP-IRAs), and savings incentive match plans for employees (SIMPLE IRAs). 2010 taxes State and municipal colleges and universities. 2010 taxes Qualified state tuition programs. 2010 taxes Medical savings accounts (MSAs) described in section 220(d). 2010 taxes Coverdell savings accounts described in section 530. 2010 taxes U. 2010 taxes S. 2010 taxes instrumentalities. 2010 taxes   A corporation that is a U. 2010 taxes S. 2010 taxes instrumentality described in section 501(c)(1) is not subject to the tax on unrelated business income if the corporation is organized under an Act of Congress and, under the Act, is exempt from federal income taxes. 2010 taxes Colleges and universities. 2010 taxes   Colleges and universities that are agencies or instrumentalities of any government or any political subdivision of a government, or that are owned or operated by a government or political subdivision of a government, are subject to the tax on unrelated business income. 2010 taxes As used here, the word government includes any foreign government (to the extent not contrary to a treaty) and all domestic governments (the United States and any of its possessions, any state, and the District of Columbia). 2010 taxes   The tax is on the unrelated business income of both the universities and colleges themselves and on their wholly owned tax exempt subsidiary organizations. 2010 taxes It is immaterial whether the business is conducted by the university or by a separately incorporated wholly owned subsidiary. 2010 taxes If the business activity is unrelated, the income in both instances will be subject to the tax. 2010 taxes If the primary purpose of a wholly owned subsidiary is to operate or conduct any unrelated trade or business (other than holding title to property and collecting income from it), the subsidiary is not an exempt organization, and this rule does not apply. 2010 taxes Title-holding corporations. 2010 taxes   When an exempt title-holding corporation, described in section 501(c)(2), pays any of its net income to an organization that itself is exempt from tax under section 501(a) (or would pay such an amount except that the expenses of collecting its income exceed the amount collected) and files a consolidated return with that organization, the title-holding corporation is treated, for unrelated business income tax purposes, as organized and operated for the same purposes as the exempt payee organization. 2010 taxes   Thus, a title-holding corporation whose source of income is related to the exempt purposes of the payee organization is not subject to the unrelated business income tax if the holding corporation and the payee organization file a consolidated return. 2010 taxes However, if the source of the income is not so related, the title-holding corporation is subject to unrelated business income tax. 2010 taxes Example. 2010 taxes X, a title-holding corporation, is required to distribute its net income to A, an exempt organization. 2010 taxes During the tax year, X realizes net income of $900,000 from source M, which is related to A's exempt function. 2010 taxes X also receives $100,000 from source N, which is not related to A's exempt function. 2010 taxes X and A file a consolidated return for the tax year. 2010 taxes X has unrelated business income of $100,000. 2010 taxes Prev  Up  Next   Home   More Online Publications
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The 2010 Taxes

2010 taxes 6. 2010 taxes   Tax Treaty Benefits Table of Contents Topics - This chapter discusses: Useful Items - You may want to see: Purpose of Tax Treaties Common Benefits Competent Authority AssistanceAdditional filing. 2010 taxes Obtaining Copies of Tax Treaties Topics - This chapter discusses: Some common tax treaty benefits, How to get help in certain situations, and How to get copies of tax treaties. 2010 taxes Useful Items - You may want to see: Publication 597 Information on the United States—Canada Income Tax Treaty 901 U. 2010 taxes S. 2010 taxes Tax Treaties See chapter 7 for information about getting these publications. 2010 taxes Purpose of Tax Treaties The United States has tax treaties or conventions with many countries. 2010 taxes See Table 6-1 at the end of this chapter for a list of these countries. 2010 taxes Under these treaties and conventions, citizens and residents of the United States who are subject to taxes imposed by the foreign countries are entitled to certain credits, deductions, exemptions, and reductions in the rate of taxes of those foreign countries. 2010 taxes If a foreign country with which the United States has a treaty imposes a tax on you, you may be entitled to benefits under the treaty. 2010 taxes Treaty benefits generally are available to residents of the United States. 2010 taxes They generally are not available to U. 2010 taxes S. 2010 taxes citizens who do not reside in the United States. 2010 taxes However, certain treaty benefits and safeguards, such as the nondiscrimination provisions, are available to U. 2010 taxes S. 2010 taxes citizens residing in the treaty countries. 2010 taxes U. 2010 taxes S. 2010 taxes citizens residing in a foreign country also may be entitled to benefits under that country's tax treaties with third countries. 2010 taxes Certification of U. 2010 taxes S. 2010 taxes residency. 2010 taxes   Use Form 8802, Application for United States Residency Certification, to request certification of U. 2010 taxes S. 2010 taxes residency for purposes of claiming benefits under a tax treaty. 2010 taxes Certification can be requested for the current and any prior calendar years. 2010 taxes You should examine the specific treaty articles to find if you are entitled to a tax credit, tax exemption, reduced rate of tax, or other treaty benefit or safeguard. 2010 taxes Common Benefits Some common tax treaty benefits are explained below. 2010 taxes The credits, deductions, exemptions, reductions in rate, and other benefits provided by tax treaties are subject to conditions and various restrictions. 2010 taxes Benefits provided by certain treaties are not provided by others. 2010 taxes Personal service income. 2010 taxes If you are a U. 2010 taxes S. 2010 taxes resident who is in a treaty country for a limited number of days in the tax year and you meet certain other requirements, the payment you receive for personal services performed in that country may be exempt from that country's income tax. 2010 taxes Professors and teachers. 2010 taxes If you are a U. 2010 taxes S. 2010 taxes resident, the payment you receive for the first 2 or 3 years that you are teaching or doing research in a treaty country may be exempt from that country's income tax. 2010 taxes Students, trainees, and apprentices. 2010 taxes If you are a U. 2010 taxes S. 2010 taxes resident, amounts you receive from the United States for study, research, or business, professional and technical training may be exempt from a treaty country's income tax. 2010 taxes Some treaties exempt grants, allowances, and awards received from governmental and certain nonprofit organizations. 2010 taxes Also, under certain circumstances, a limited amount of pay received by students, trainees, and apprentices may be exempt from the income tax of many treaty countries. 2010 taxes Pensions and annuities. 2010 taxes If you are a U. 2010 taxes S. 2010 taxes resident, nongovernment pensions and annuities you receive may be exempt from the income tax of treaty countries. 2010 taxes Most treaties contain separate provisions for exempting government pensions and annuities from treaty country income tax, and some treaties provide exemption from the treaty country's income tax for social security payments. 2010 taxes Investment income. 2010 taxes If you are a U. 2010 taxes S. 2010 taxes resident, investment income, such as interest and dividends, that you receive from sources in a treaty country may be exempt from that country's income tax or taxed at a reduced rate. 2010 taxes Several treaties provide exemption for capital gains (other than from sales of real property in most cases) if specified requirements are met. 2010 taxes Tax credit provisions. 2010 taxes If you are a U. 2010 taxes S. 2010 taxes resident who receives income from or owns capital in a foreign country, you may be taxed on that income or capital by both the United States and the treaty country. 2010 taxes Most treaties allow you to take a credit against or deduction from the treaty country's taxes based on the U. 2010 taxes S. 2010 taxes tax on the income. 2010 taxes Nondiscrimination provisions. 2010 taxes Most U. 2010 taxes S. 2010 taxes tax treaties provide that the treaty country cannot discriminate by imposing more burdensome taxes on U. 2010 taxes S. 2010 taxes citizens who are residents of the treaty country than it imposes on its own citizens in the same circumstances. 2010 taxes Saving clauses. 2010 taxes U. 2010 taxes S. 2010 taxes treaties contain saving clauses that provide that the treaties do not affect the U. 2010 taxes S. 2010 taxes taxation of its own citizens and residents. 2010 taxes As a result, U. 2010 taxes S. 2010 taxes citizens and residents generally cannot use the treaty to reduce their U. 2010 taxes S. 2010 taxes tax liability. 2010 taxes However, most treaties provide exceptions to saving clauses that allow certain provisions of the treaty to be claimed by U. 2010 taxes S. 2010 taxes citizens or residents. 2010 taxes It is important that you examine the applicable saving clause to determine if an exception applies. 2010 taxes More information on treaties. 2010 taxes   Publication 901 contains an explanation of treaty provisions that apply to amounts received by teachers, students, workers, and government employees and pensioners who are alien nonresidents or residents of the United States. 2010 taxes Since treaty provisions generally are reciprocal, you usually can substitute “United States” for the name of the treaty country whenever it appears, and vice versa when “U. 2010 taxes S. 2010 taxes ” appears in the treaty exemption discussions in Publication 901. 2010 taxes   Publication 597 contains an explanation of a number of frequently-used provisions of the United States–Canada income tax treaty. 2010 taxes Competent Authority Assistance If you are a U. 2010 taxes S. 2010 taxes citizen or resident alien, you can request assistance from the U. 2010 taxes S. 2010 taxes 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. 2010 taxes You should read any treaty articles, including the mutual agreement procedure article, that apply in your situation. 2010 taxes The U. 2010 taxes S. 2010 taxes competent authority cannot consider requests involving countries with which the United States does not have a tax treaty. 2010 taxes Effect of request for assistance. 2010 taxes   If your request provides a basis for competent authority assistance, the U. 2010 taxes S. 2010 taxes competent authority generally will consult with the treaty country competent authority on how to resolve the situation. 2010 taxes How to make your request. 2010 taxes   It is important that you make your request for competent authority consideration as soon as either of the following occurs. 2010 taxes You are denied treaty benefits. 2010 taxes Actions taken by both the United States and the foreign country result in double taxation or will result in taxation not intended by the treaty. 2010 taxes   In addition to making a request for assistance, you should take steps so that any agreement reached by the competent authorities is not barred by administrative, legal, or procedural barriers. 2010 taxes Some of the steps you should consider taking include the following. 2010 taxes Filing a protective claim for credit or refund of U. 2010 taxes S. 2010 taxes taxes. 2010 taxes Delaying the expiration of any period of limitations on the making of a refund or other tax adjustment. 2010 taxes Avoiding the lapse or termination of your right to appeal any tax determination. 2010 taxes Complying with all applicable procedures for invoking competent authority consideration. 2010 taxes Contesting an adjustment or seeking an appropriate correlative adjustment with respect to the U. 2010 taxes S. 2010 taxes or treaty country tax. 2010 taxes Taxpayers can consult with the U. 2010 taxes S. 2010 taxes competent authority to determine whether they need to take protective steps and when any required steps need to be taken. 2010 taxes   The request should contain all essential items of information, including the following items. 2010 taxes A reference to the treaty and the treaty provisions on which the request is based. 2010 taxes The years and amounts involved in both U. 2010 taxes S. 2010 taxes dollars and foreign currency. 2010 taxes A brief description of the issues for which competent authority assistance is requested. 2010 taxes   A complete listing of the information that must be included with the request can be found in Revenue Procedure 2006-54, or its successor. 2010 taxes Revenue Procedure 2006-54 is available at www. 2010 taxes irs. 2010 taxes gov/irb/2006-49_IRB/ar13. 2010 taxes html. 2010 taxes   Also, see Notice 2013-78, which provides proposed updates to the procedures for requesting U. 2010 taxes S. 2010 taxes competent authority assistance under tax treaties. 2010 taxes As noted, Revenue Procedure 2006-54 will be superseded by a revenue procedure to be published in the future. 2010 taxes    Your request for competent authority consideration should be addressed to:   Deputy Commissioner (International) Large Business and International Division Internal Revenue Service 1111 Constitution Avenue, NW Routing M4-365 Washington, DC 20224 Attn: TAIT Additional filing. 2010 taxes   In the case of U. 2010 taxes S. 2010 taxes - initiated adjustments, you also must file a copy of the request with the IRS office where your case is pending. 2010 taxes If the request is filed after the matter has been designated for litigation or while a suit contesting your relevant tax liability is pending in a United States court, a copy of the request, with a separate statement attached identifying the court where the suit is pending and the docket number of the action, also must be filed with the: Office of Associate Chief Counsel (International) Internal Revenue Service 1111 Constitution Avenue, NW Washington, DC 20224 Additional details on the procedures for requesting competent authority assistance are included in Revenue Procedure 2006-54, or its successor. 2010 taxes Obtaining Copies of Tax Treaties Table 6-1 lists those countries with which the United States has income tax treaties. 2010 taxes This table is updated through October 31, 2013. 2010 taxes You can get complete information about treaty provisions from the taxing authority in the country from which you receive income or from the treaty itself. 2010 taxes You can obtain the text of most U. 2010 taxes S. 2010 taxes treaties at IRS. 2010 taxes gov. 2010 taxes You also can request the text of treaties from the Department of Treasury at the following address. 2010 taxes Department of Treasury Office of Business and Public Liaison Rm. 2010 taxes 3411 1500 Pennsylvania Avenue, NW  Washington, DC 20220 If you have questions about a treaty and you are in the United States, Puerto Rico, or the U. 2010 taxes S. 2010 taxes Virgin Islands, you can call the IRS at 1-800-829-1040. 2010 taxes Table 6–1. 2010 taxes List of Tax Treaties (Updated through October 31, 2013) Country Official Text  Symbol1 General  Effective Date Citation Applicable Treasury Explanations  or Treasury Decision (T. 2010 taxes D. 2010 taxes ) Australia TIAS 10773 Dec. 2010 taxes 1, 1983 1986-2 C. 2010 taxes B. 2010 taxes 220 1986-2 C. 2010 taxes B. 2010 taxes 246 Protocol TIAS Jan. 2010 taxes 1, 2004     Austria TIAS Jan. 2010 taxes 1, 1999     Bangladesh TIAS Jan. 2010 taxes 1, 2007     Barbados TIAS 11090 Jan. 2010 taxes 1, 1984 1991-2 C. 2010 taxes B. 2010 taxes 436 1991-2 C. 2010 taxes B. 2010 taxes 466 Protocol TIAS Jan. 2010 taxes 1, 2005     Belgium TIAS Jan. 2010 taxes 1, 2008     Bulgaria TIAS Jan. 2010 taxes 1, 2009     Canada2 TIAS 11087 Jan. 2010 taxes 1, 1985 1986-2 C. 2010 taxes B. 2010 taxes 258 1987-2 C. 2010 taxes B. 2010 taxes 298 Protocol TIAS Jan. 2010 taxes 1, 2009     China, People's Republic of TIAS 12065 Jan. 2010 taxes 1, 1987 1988-1 C. 2010 taxes B. 2010 taxes 414 1988-1 C. 2010 taxes B. 2010 taxes 447 Commonwealth of Independent States3 TIAS 8225 Jan. 2010 taxes 1, 1976 1976-2 C. 2010 taxes B. 2010 taxes 463 1976-2 C. 2010 taxes B. 2010 taxes 475 Cyprus TIAS 10965 Jan. 2010 taxes 1, 1986 1989-2 C. 2010 taxes B. 2010 taxes 280 1989-2 C. 2010 taxes B. 2010 taxes 314 Czech Republic TIAS Jan. 2010 taxes 1, 1993     Denmark TIAS Jan. 2010 taxes 1, 2001     Protocol TIAS Jan. 2010 taxes 1, 2008     Egypt TIAS 10149 Jan. 2010 taxes 1, 1982 1982-1 C. 2010 taxes B. 2010 taxes 219 1982-1 C. 2010 taxes B. 2010 taxes 243 Estonia TIAS Jan. 2010 taxes 1, 2000     Finland TIAS 12101 Jan. 2010 taxes 1, 1991     Protocol TIAS Jan. 2010 taxes 1, 2008     France TIAS Jan. 2010 taxes 1, 1996     Protocol TIAS Jan. 2010 taxes 1, 2009     Germany TIAS Jan. 2010 taxes 1, 1990     Protocol TIAS Jan. 2010 taxes 1, 2008     Greece TIAS 2902 Jan. 2010 taxes 1, 1953 1958-2 C. 2010 taxes B. 2010 taxes 1054 T. 2010 taxes D. 2010 taxes 6109, 1954-2 C. 2010 taxes B. 2010 taxes 638 Hungary TIAS 9560 Jan. 2010 taxes 1, 1980 1980-1 C. 2010 taxes B. 2010 taxes 333 1980-1 C. 2010 taxes B. 2010 taxes 354 Iceland TIAS 8151 Jan. 2010 taxes 1, 2009     India TIAS Jan. 2010 taxes 1, 1991     Indonesia TIAS 11593 Jan. 2010 taxes 1, 1990     Ireland TIAS Jan. 2010 taxes 1, 1998     Israel TIAS Jan. 2010 taxes 1, 1995     Italy TIAS Jan. 2010 taxes 1, 2010     Jamaica TIAS 10207 Jan. 2010 taxes 1, 1982 1982-1 C. 2010 taxes B. 2010 taxes 257 1982-1 C. 2010 taxes B. 2010 taxes 291 Japan TIAS Jan. 2010 taxes 1, 2005     Kazakhstan TIAS Jan. 2010 taxes 1, 1996     Korea, South TIAS 9506 Jan. 2010 taxes 1, 1980 1979-2 C. 2010 taxes B. 2010 taxes 435 1979-2 C. 2010 taxes B. 2010 taxes 458 Latvia TIAS Jan. 2010 taxes 1, 2000     Lithuania TIAS Jan. 2010 taxes 1, 2000     Luxembourg TIAS Jan. 2010 taxes 1, 2001     Malta TIAS Jan. 2010 taxes 1, 2011     Mexico TIAS Jan. 2010 taxes 1,1994     Protocol TIAS Jan. 2010 taxes 1, 2004               Table 6–1 (continued). 2010 taxes Country Official Text  Symbol1 General  Effective Date Citation Applicable Treasury Explanations  or Treasury Decision (T. 2010 taxes D. 2010 taxes ) Morocco TIAS 10195 Jan. 2010 taxes 1, 1981 1982-2 C. 2010 taxes B. 2010 taxes 405 1982-2 C. 2010 taxes B. 2010 taxes 427 Netherlands TIAS Jan. 2010 taxes 1, 1994     Protocol TIAS Jan. 2010 taxes 1, 2005     New Zealand TIAS 10772 Nov. 2010 taxes 2, 1983 1990-2 C. 2010 taxes B. 2010 taxes 274 1990-2 C. 2010 taxes B. 2010 taxes 303 Protocol TIAS Jan. 2010 taxes 1, 2011     Norway TIAS 7474 Jan. 2010 taxes 1, 1971 1973-1 C. 2010 taxes B. 2010 taxes 669 1973-1 C. 2010 taxes B. 2010 taxes 693 Protocol TIAS 10205 Jan. 2010 taxes 1, 1982 1982-2 C. 2010 taxes B. 2010 taxes 440 1982-2 C. 2010 taxes B. 2010 taxes 454 Pakistan TIAS 4232 Jan. 2010 taxes 1, 1959 1960-2 C. 2010 taxes B. 2010 taxes 646 T. 2010 taxes D. 2010 taxes 6431, 1960-1 C. 2010 taxes B. 2010 taxes 755 Philippines TIAS 10417 Jan. 2010 taxes 1, 1983 1984-2 C. 2010 taxes B. 2010 taxes 384 1984-2 C. 2010 taxes B. 2010 taxes 412 Poland TIAS 8486 Jan. 2010 taxes 1, 1974 1977-1 C. 2010 taxes B. 2010 taxes 416 1977-1 C. 2010 taxes B. 2010 taxes 427 Portugal TIAS Jan. 2010 taxes 1, 1996     Romania TIAS 8228 Jan. 2010 taxes 1, 1974 1976-2 C. 2010 taxes B. 2010 taxes 492 1976-2 C. 2010 taxes B. 2010 taxes 504 Russia TIAS Jan. 2010 taxes 1, 1994     Slovak Republic TIAS Jan. 2010 taxes 1, 1993     Slovenia TIAS Jan. 2010 taxes 1, 2002     South Africa TIAS Jan. 2010 taxes 1, 1998     Spain TIAS Jan. 2010 taxes 1, 1991     Sri Lanka TIAS Jan. 2010 taxes 1, 2004     Sweden TIAS Jan. 2010 taxes 1, 1996     Protocol TIAS Jan. 2010 taxes 1, 2007     Switzerland TIAS Jan. 2010 taxes 1, 1998     Thailand TIAS Jan. 2010 taxes 1, 1998     Trinidad and Tobago TIAS 7047 Jan. 2010 taxes 1, 1970 1971-2 C. 2010 taxes B. 2010 taxes 479   Tunisia TIAS Jan. 2010 taxes 1, 1990     Turkey TIAS Jan. 2010 taxes 1, 1998     Ukraine TIAS Jan. 2010 taxes 1, 2001     United Kingdom TIAS Jan. 2010 taxes 1, 2004     Venezuela TIAS Jan. 2010 taxes 1, 2000      1(TIAS) — Treaties and Other International Act Series. 2010 taxes  2Information on the treaty can be found in Publication 597, Information on the United States—Canada Income Tax Treaty. 2010 taxes 3The U. 2010 taxes S. 2010 taxes -U. 2010 taxes S. 2010 taxes S. 2010 taxes R. 2010 taxes income tax treaty applies to the countries of Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan. 2010 taxes Prev  Up  Next   Home   More Online Publications