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IRS Treaty Country Listing as of April 2008

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IRS Treaty Country Listing as of April 2008

Postby Riser Adkisson LLP » Sun Dec 14, 2008 8:14 am

SOURCE: Foreign Insurance Excise Tax - Audit Technique Guide, April 2008, as found at ... 63,00.html NOTE: This document is not an official pronouncement of the law or the position of the Service and can not be used, cited, or relied upon as such. This guide is current through the publication date. Since changes may have occurred after the publication date that would affect the accuracy of this document, no guarantees are made concerning the technical accuracy after the publication date.


Treaty Country Listing as of April 2008
Treaty Country Effective Date Limited by Anti-Conduit Provision
Cyprus 1-1-86 Yes
Finland 1-1-91 Yes
France 2-1-96 Yes
Germany 1-1-90 Yes
India 1-1-91 Yes
Ireland 1-1-98 Yes
Israel 1-1-95 Yes
Italy 1-1-85 Yes
Japan 1-1-05 Yes
Luxembourg 1-1-01 Yes
Mexico 1-1-94 Yes
Netherlands 1-1-94 Yes
Sweden 1-1-96 Yes
Switzerland 1-1-98 Yes
Spain 1-1-91 Yes
United Kingdom 1-1-04** Yes***

Treaty Country Effective Date Limited by Anti-Conduit Provision
Hungary 1-1-80 to Current No
Romania 1-1-74 to Current No
United Kingdom 1-1-75 to 12-31-03** No
USSR * 1-1-76 to Current No
* In effect for Armenia, Azerbaijan, Belarus, Georgia, Kazakhstan, Kyrgyz Republic, Moldova, Tajikistan, Turkmenistan, Ukraine, and Uzbekistan. Although Russia entered into a separate treaty with the United States in 1992, it does not contain an insurance premium excise tax exemption.

** Effective date is extended one year to 1-1-05 for U.K. entities which elect to have the provisions of the old treaty apply for the first 12 months.

*** The transaction is exempt unless the policies are entered into as a part of a conduit arranged to reduce the tax due.
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