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Form 8833 Treaty-Based Return Positions

YesNoNoYesNoYesWas the position that a treaty exempts from tax, or reduces the rate of tax on, [ ] fixed or determinable annual or periodical income subject to withholding under section 1441 or 1442 that a foreign person receives from a person? SourceFDAPReg. (b)(4)(ii), -1(c)(1)(i)NoYesNoNoYesHas a closing agreement relating to entitlement to the exemption from the excise tax been entered into with the IRS by the foreign insurance company that is the beneficial recipient of the premium that is subject to the excise tax?Reg. (c)(1)(viii)(C)Closing AgreementYesNoNoHas the taxpayer taken a Return position that any treaty of the (including, but not limited to, an income tax treaty , estate and gift tax treaty , or friendship, commerce and navigation treaty ) overrules or modifies any provision of the Code and thereby effects (or potentially effects) a reduction of any tax incurred as any time?

Yes No No Yes No Was the position that Yes a treaty exempts from tax, or reduces the rate of tax on, [U.S. source] fixed or determinable annual or periodical income

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  Form, Based, Position, Return, Treaty, 3388, Form 8833 treaty based return positions

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Transcription of Form 8833 Treaty-Based Return Positions

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