The Resource Nazione non più favorita? Despite MFN clause, IRS taxes salaries of certain green card holders working for Italian consulates

Nazione non più favorita? Despite MFN clause, IRS taxes salaries of certain green card holders working for Italian consulates

Label
Nazione non più favorita? Despite MFN clause, IRS taxes salaries of certain green card holders working for Italian consulates
Title
Nazione non più favorita? Despite MFN clause, IRS taxes salaries of certain green card holders working for Italian consulates
Creator
Subject
Language
eng
Summary
In CCA 201212008, the Internal Revenue Service (IRS) Chief Counsel held that Italian citizens employed by the Italian consulates in the US are generally subject to US income tax on their salaries if they are lawful permanent residents of the US (US green card holders) and are not recognized as "Consular officers" by the US State Department. This is in sharp contrast to Announcement 2010-2, in which the IRS stated that German citizens employed by the German consulates in the US are exempt from US income tax on their salaries, even if they hold US green cards and are not Consular officers. Although CCA 201212008 is purportedly based upon the US-Italy agreement titled "Rights, Privileges, and Immunities of Consular Officers" (US-Italy Consular Treaty), which took effect in 1878, strikingly absent is any mention of the Most Favoured Nation (MFN) clause, contained in Article 17 of the US-Italy Consular Treaty
Citation source
In: Tax management international journal. - Arlington. - Vol. 41 (2012),
http://library.link/vocab/creatorName
Lederman, A.S
Language note
English
http://library.link/vocab/subjectName
  • MFN
  • tax treaty
  • employment income
  • green card
Label
Nazione non più favorita? Despite MFN clause, IRS taxes salaries of certain green card holders working for Italian consulates
Instantiates
Publication
Label
Nazione non più favorita? Despite MFN clause, IRS taxes salaries of certain green card holders working for Italian consulates
Publication

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