Upon completion of this course, you should be able to: Describe the purpose of income tax treaties in the tax regimes of countries; Identify common provisions in the U.S. Model Treaty; Define the "tie-breaker" rule when a person qualifies as a resident in more than one country; Describe the rules by which any taxpayer claiming the benefits of a treaty by taking a tax return position that is in conflict with the Internal Revenue Code must disclose the position; Recognize qualifications for a permanent establishment; Identify dividend rates that are most likely to be taxes; Describe how to prevent treaty shopping; Identify treaty countries and the rates for foreign clientele; Recognize criteria that would most likely pass the connected services test; Describe exemptions or reductions by tax treaties; Identify and apply the six tests that place limitations on treaty benefits and prevent treaty shopping; Differentiate the mutual agreement procedure between the taxing authorities of two treaty countries in cases of double taxation; Identify which form a company needs to file with the IRS to show that it is exempt from taxation; Recognize when a company/citizen would need to file Form W8-BEN with the IRS in order to claim treaty benefits for U.S. tax withholding.