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Georgetown Law Library

International and Foreign Tax Law Research Guide

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

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U.S. Tax Treaties (Including Superseded & Terminated Treaties)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access to the texts of all types of U.S. tax treaties, regardless of their status (in-force, pending ratification, superseded, terminated, etc.):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  Also available on Bloomberg Law
    Content may be browsed alphabetically by treaty partner or searched by keyword.  Use the Bloomberg platform to download content in PDF format.
     
  • CCH (Wolters Kluwer) International Tax Library
    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
    Select Treaties as the collection.  Then use the filters on the left to narrow by country (United States), related country, treaty subject, and treaty status.  Specify a date range, if desired.
     
  • Tax Treaties & Conventions 
    This easy-to-search Westlaw database includes current and superseded U.S. tax treaties from 1844 - present.  To search by treaty party, enter the country name in the title field of the search template.  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 mouse over U.S. Tax Treaties - WG&L and click on the book-shaped icon.  Content is arranged alphabetically by treaty partner.  Above the text of each treaty article, you will find links to analysis and commentary from the respected Warren, Gorham & Lamont tax treatise series.
     
  • Federal Tax Coordinator 2d.  KF6285 .F4 1984  
    Volume 20A of this regularly updated loose leaf set contains the verbatim texts of all types of current and superseded U.S. tax treaties.  Volume 20 provides explanatory analysis of U.S. income tax treaties (primarily those that are currently in force, but a few superseded treaties also are analyzed).
      
  • 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, while Part IV analyzes other types of U.S. tax treaties.
     
  • TaxNotes.com 
    From the Research Tools tab in the upper right-hand corner of the homepage, click on Worldwide Tax Treaties.  Use the Quick Treaty Locator on the left side to search.  Or click on Browse Treaties and use the filters to narrow by country, treaty type or treaty status.  To access summaries of U.S. income tax treaty currently in force, click on the appropriate link under the heading News and Analysis on the lower left-hand side of the page.
     

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.

  • CCH (Wolters Kluwer) International Tax Library 
    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.  Then select the desired treaty partner and treaty.  Scroll all the way down to view the legislative history documents.
     
  • Checkpoint 
    Select International Tax as the practice area.  Then click on the + sign next to Tax Treaties under Primary Source Materials.  Hover your mouse 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.
     
  • 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 Research Tools tab in the upper right-hand corner of the homepage, click on Worldwide Tax Treaties.  Then click on U.S. Legislative History under the heading Models and Documents on the lower left-hand side of the page.  Use the filters to narrow by document type and treaty partner.
     
  • Worldwide Tax Treaties U.S. Legislative Histories  
    The content of this searchable Lexis database is identical to the tax treaty legislative history database available on TaxNotes.com.  To browse for legislative histories by treaty partner, use the TaxNotes platform.