U.S. Income Taxation of Foreign Governments, International Organizations, Central Banks and Their Employees, BNA Tax Management Portfolio 913-4th

This leading treatise discussed the income tax exemptions under §§892, 893, and 895 of the U.S. Internal Revenue Code of 1986. It discusses the development of the exemption under §892 for foreign governments and international organizations, particularly the limitations placed on the scope of the exemption by the 1986 Tax Reform Act and by the 1988 Temporary Regulations.

The Portfolio analyzes in detail what types of organizations are exempt from tax and what kinds of income received by such organizations are exempt from tax. There is an extensive analysis of the issues raised by the regulations under §892 and the ambiguities still present in the law. Tax planning suggestions are also presented and analyzed. The treatise also discusses §893, which exempts employees of foreign governments and international organizations from income tax, and §895, which exempts foreign central banks from income tax. In addition, it raises the possibility of exemption through income tax treaties and other international agreements.