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Georgetown Law Library

International and Foreign Tax Law Research Guide

This guide is a starting point for researching international and foreign tax law.

U.S. Bilateral Tax Treaties

Table of Contents

Quick Links to U.S. Income Tax Treaties Currently in Force

For quick access to the texts of U.S. income tax treaties currently in force, consult the following resources:

  • United States Income Tax Treaties - A to Z
    The IRS provides free online access to U.S. income tax treaties currently in force, plus a handful of terminated income tax treaties.  Treaties are arranged alphabetically by treaty partner and may be downloaded in PDF format.  Protocols (amendments) and technical explanations issued by the Treasury Department also are available.
     
  • Internal Revenue Bulletin. Available in print:  KF6301 .A12 (1992 - 2012); and online (1996 - ). 
    Recently ratified U.S. tax treaties and related documents are published in Part II of this weekly publication.  If you have a known date or date range to use as a starting point, this can be a good source for newly ratified treaties, as it is often the first place that they are published.
     

U.S. Tax Treaties (Including Superseded & Terminated Treaties)

The following platforms provide access to the texts of all types of U.S. tax treaties, regardless of their status (in-force, pending ratification, superseded, terminated, etc.):

  • BNA U.S. Tax Treaties on Bloomberg Law Tax
    Content may be browsed alphabetically by treaty partner or searched by keyword.  Use the Bloomberg platform to download content in PDF format.
     
  • VitalLaw (formerly Cheetah)
    Click on the link to the U.S. Tax Treaties Reporter under the Tax Treaties heading.  After the page refreshes, select U.S. Treaties and Agreements from the menu on the left.  Content is arranged alphabetically by treaty partner and may be downloaded in PDF format.
     
  • IBFD Tax Research Platform
    Make sure that Search is selected in light blue menu bar at the top of the page.  Select Treaties & Models from the content menu below the search box.  Then use the filters on the left to narrow by country/jurisdiction (United States), related country, treaty subject, and treaty status.  Specify a date range, if desired.
     
  • TaxNotes.com
    From the Subscriptions menu in the upper right-hand corner of the homepage, select Worldwide Tax Treaties.  After the page refreshes, use the Quick Treaty Locator to access the texts of U.S. bilateral income tax treaties that are currently in force.  To search more broadly for U.S. bilateral tax treaties, covering all subjects and statuses (in force, terminated, and superseded), click on Treaties in the center of the page.  After the page refreshes, use the search form to locate the desired treaty. 
     
  • Tax Treaties & Conventions 
    This easy-to-search Westlaw database includes current and superseded U.S. tax treaties from 1844 - present.  To search by treaty partner, use the Advanced Search template and scroll down to enter the name of the treaty partner in the Country Name field.  Specify a date range, if desired.
     

Texts of U.S. Tax Treaties with Analysis and Commentary

In addition to current and superseded U.S. tax treaties, these platforms also provide explanatory commentary and analysis:

  • Checkpoint 
    Select International Tax as the practice area.  Then click on the + sign next to Tax Treaties under Primary Source Materials.  Hover your cursor over U.S. Tax Treaties - WG&L and click on the book-shaped icon.  Content is arranged alphabetically by treaty partner.  When you display an article of a bilateral tax treaty in your browser, you will find links to analysis and commentary embedded above and within the text of the article.   These include Technical Explanations from the U.S. Treasury, as well as Analysis and Editorial Explanations from the respected Warren, Gorham & Lamont tax treatise series.
     
  • Rhoades & Langer U.S. International Taxation & Tax Treaties
    Appendix A of this Lexis treatise includes the full texts of current and superseded U.S. tax treaties and agreements.  Part III provides explanatory analysis of U.S. income tax treaties, organized by subject matter.  Part IV analyzes other types of U.S. tax treaties.
     
  • Federal Tax Coordinator 2d.  KF6285 .F4 1984  (last updated in 2019)
    Although it is no longer updated in print, this loose-leaf set may still be useful for historical research.  Volume 20 provides explanatory analysis of U.S. income tax treaties (current as of the last print update in 2019).  Volume 20A includes the texts of all types of U.S. tax treaties (current as of the last print update in 2019).  Note:  Regularly updated content from the Federal Tax Coordinator, including explanatory analysis of U.S. tax treaties, is available on Checkpoint. (see the description above for details). 
     

Legislative Histories of U.S. Tax Treaties

Legislative history documents include congressional reports issued by the U.S. Senate's Foreign Relations Committee and by the Joint Committee on Taxation, as well as technical explanations issued by the U.S. Treasury Department.

  • Checkpoint 
    Select International Tax as the practice area.  Then click on the + sign next to Tax Treaties under Primary Source Materials.  Hover your cursor over U.S. Tax Treaties - WG&L and click on the book-shaped icon.  Treaty texts and legislative history documents are arranged alphabetically by treaty partner.
     
  • VitalLaw (formerly Cheetah)
    Click on the link to the U.S. Tax Treaties Reporter under the heading Treaties.  After the page refreshes, select U.S. Treaties and Agreements from the menu on the left.  Then select the desired jurisdiction and treaty.  Use the menu on the left to scroll down and select letters of transmittal, Senate committee reports, technical explanations, and other legislative history documents.
     
  • Legislative History of United States Tax ConventionsKF6306 .L43 1986r (No longer updated after 2006.) 
    Although this 21-volume loose leaf set is no longer updated, it remains an excellent source for accessing compiled legislative histories of U.S. tax treaties that entered into force in 2006 or earlier.
      
  • IRS website
    Provides free online access to technical explanations issued by the U.S. Treasury Department for income tax treaties currently in force.  No other legislative history documents are available on the website.
     
  • TaxNotes.com
    From the Subscriptions menu in the upper right-hand corner of the homepage select Worldwide Tax Treaties.  After the page refreshes, select U.S. Legislative Histories from the menu.  After the page refreshes again, use the jurisdictions menu to select the desired treaty partner and the Document Type menu to select the desired treaty.