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Federal Tax Research Guide: U.S. Tax Treaties/Agreements

A guide to Brooklyn Law School's federal tax resources. Call numbers are specific to Brooklyn Law School Library.

Subscription: U.S. Tax Treaties/Agreements & Analysis

U.S. tax treaties/agreements & analysis:

Bloomberg Law: U.S. Tax Treaties (and other agreements)

This source is searchable and supports filtering of results by: treaty status (in-force, not-in-force, terminated and superseded); topic (Competent Authority Agreements, FATCA Agreements, Income Tax Treaties, Mutual Assistance Agreements, Social Security Agreements, Tax Information Exchange Agreements, Transfer Tax Agreements and Transportation Tax Agreements); and country.

Bloomberg Law: International [tax] page

This page of sources includes a tax Treaty Primer and a treaty finder (by country).

It links to collections of both U.S. Tax Treaties and International Tax Treaties (including treaties to which the U.S. is not a party); a Treaty Comparison Tool. a tool to identify Treaties Modified By BEPS MLI and Effective Dates; and OECD Two-Pillar Global Tax Agreement Watch.  Box "News & Journals" links to Daily Tax Report: International, and an International Tax Developments Tracker.

On p. 114 of Federal Tax Research: Guide to Materials and Techniques (2021), Richmond and Yamamoto note that if Bloomberg Law offers a Business Operations in ... Portfolio for a country, researchers might be able to find cites to key cases and other documents in the Detailed Analysis section of the Portfolio.  BLS researchers: you might need to contact Bloomberg Law to try to determine the DATE of information provided in a Business Operations Portfolio.

International Bureau of Fiscal Documentation, subscription IBFD Tax Research Platform > in BLS Library's catalog record, click: ACCESS ONLINE VERSION (IBFD) > in the IBFD Tax Research Platform, click: Search > beneath search box, click category: Treaties & Models

TIP: One can filter treaties by: country/jurisdiction (including option: United States), treaty status, bilateral/multilateral and topic.  Also, one can run keyword searches. 

(Access IBFD Tax Research Platform on campus, in BLS housing, and elsewhere off campus if one has implemented the BLS proxy server instructions.)

Lexis+: Rufus Rhoades & Marshall Langer, Rhoades and Langer U.S. International Taxation and Tax Treaties (updated quarterly)

According to the preface, this source analyzes "most of the tax sections of the Internal Revenue Code that affect international activities. It covers both outbound and inbound transactions, as well as the impact of tax treaties on these transactions."  Appendix A provides tax treaties and agreements between the U.S. and other countries/territories. Appendix B provides U.S. model tax treaties.

VitalLaw: U.S. Tax Treaties Reporter (treaty contents, as described by publisher: U.S. "income and estate tax treaties that have been released, along with exchange-of-information agreements, Caribbean Basin agreements, Social Security and shipping and aircraft agreements")

Section: U.S. Treaties and Agreements of this Reporter provides texts arranged alphabetically by country name.  Following a treaty's text, there is either text of, or references to, U.S. government analysis of the treaty (e.g., reports of the U.S. Department of State, Department of the Treasury and/or Senate Foreign Relations Committee).  Following a treaty's text, there might be Annotations of/links to pertinent administrative rulings and court cases.  This Reporter also includes New Developments (including case developments) and Amended Treaties (a CCH Amended Treaty "reflects original treaty text as amended by later protocols"). 

Westlaw: RIA International Tax Treaties + [RIA's] Editorial Explanations

This source contains: RIA International Tax Treaties and RIA International Tax Treaty Editorial Explanations.

Analysis & new developments:

VitalLaw: Standard Federal Tax Reporter (2024)

According to the publisher, this Code-arranged CCH Reporter provides "extensive coverage" of international tax transactions. In the table of contents, click: Foreign Income and Tax Treaties - Secs. 861 - 999

Analysis includes: ¶ 26,805 Tax Treaties; ¶26,810 Treaty Negotiation and Ratification Steps; ¶ 26,812 U.S. Model Income Tax Treaty; and  ¶ 26,815 Summaries of [specific] Treaties.

At the beginning of the table of contents, there also is a link to Federal Tax Current Developments by Code Section Smart Chart.

Subscription: U.S. Tax Treaty History

HeinOnline: Sidney I. Roberts, ed., Legislative History of United States Tax Conventions: Roberts & Holland Collection (w/ 2020 supplement) (21 vols.)

In BLS Library's catalog record, click: ACCESS ONLINE VERSION - HEIN.  This is a country-arranged collection of U.S. tax treaties + tax treaty history documents.

Free: U.S. Tax Treaties/Agreements at U.S. Government Websites

Tip: Researchers who wish to apply Bluebook rule 21.4.5(a) and to cite U.S. tax treaties/other international agreements in the currently published Treaties and Other International Acts Series (T.I.A.S.) or in the previously published United States Treaties and Other International Agreements series (U.S.T.) should access this page of BLS Library's Treaty Research Guide.

U.S. IRS, United States Income Tax Treaties A - Z provides U.S. income tax treaties and (in many instances) accompanying Technical Explanations.  

On p. 102 of Federal Tax Research: Guide to Materials and Techniques (2021), Richmond and Yamamoto note that the U.S. Department of the Treasury's Office of Tax Policy is primarily responsible for negotiating U.S. tax treaties.  On p. 103, these authors explain that the Treasury Department creates Technical Explanations of U.S. tax treaties to aid the U.S. Senate Foreign Relations Committee.

U.S. Department of the Treasury, International Tax provides: recently signed U.S. income tax treaties + accompanying Technical Explanations; the current U.S. Model Income Tax Convention; U.S. Tax Information Exchange Agreements (TIEAs); and a table (with links to documents) of Foreign Account Tax Compliance Act (FATCA) Agreements and Understandings in Effect by Jurisdiction.

Free: U.S. Government Websites Providing Information & U.S. Tax Treaty History

U.S. IRS,

Internal Revenue Bulletins include Part II, Subpart A: Tax Conventions and Other Related ItemsPart IV, Announcements also might provide useful information. 

International Individuals contains tax information for U.S. citizens and resident aliens.

International Business includes information about transfer pricing and links to Form 8975 Country-by-Country Report Filing Rules applicable to U.S. MNEs.

Congress.gov, Treaty Documents

Congress.gov follows the progress of treaties through the U.S. Senate.  Tip: Review About Treaty Documents prior to searching this collection.

Scope of available treaty documents: 94th Congress (1975-1976) - present + treaty documents for treaties submitted prior to 94th Congress that were pending in 1975.

U.S. Government Publishing Office, GovInfo