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E File 2011 Taxes Late

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E File 2011 Taxes Late

E file 2011 taxes late 1. E file 2011 taxes late   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). E file 2011 taxes late 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). E file 2011 taxes late In addition, the following are subject to the tax on unrelated business income. E file 2011 taxes late 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). E file 2011 taxes late State and municipal colleges and universities. E file 2011 taxes late Qualified state tuition programs. E file 2011 taxes late Medical savings accounts (MSAs) described in section 220(d). E file 2011 taxes late Coverdell savings accounts described in section 530. E file 2011 taxes late U. E file 2011 taxes late S. E file 2011 taxes late instrumentalities. E file 2011 taxes late   A corporation that is a U. E file 2011 taxes late S. E file 2011 taxes late 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. E file 2011 taxes late Colleges and universities. E file 2011 taxes late   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. E file 2011 taxes late 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). E file 2011 taxes late   The tax is on the unrelated business income of both the universities and colleges themselves and on their wholly owned tax exempt subsidiary organizations. E file 2011 taxes late It is immaterial whether the business is conducted by the university or by a separately incorporated wholly owned subsidiary. E file 2011 taxes late If the business activity is unrelated, the income in both instances will be subject to the tax. E file 2011 taxes late 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. E file 2011 taxes late Title-holding corporations. E file 2011 taxes late   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. E file 2011 taxes late   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. E file 2011 taxes late However, if the source of the income is not so related, the title-holding corporation is subject to unrelated business income tax. E file 2011 taxes late Example. E file 2011 taxes late X, a title-holding corporation, is required to distribute its net income to A, an exempt organization. E file 2011 taxes late During the tax year, X realizes net income of $900,000 from source M, which is related to A's exempt function. E file 2011 taxes late X also receives $100,000 from source N, which is not related to A's exempt function. E file 2011 taxes late X and A file a consolidated return for the tax year. E file 2011 taxes late X has unrelated business income of $100,000. E file 2011 taxes late Prev  Up  Next   Home   More Online Publications
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The E File 2011 Taxes Late

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