Explain the treaty-based return position taken. Include a brief summary of the facts on which it is based. Also, list the nature
List the provision(s) of the limitation on benefits article (if any) in the treaty that the taxpayer relies on to prevent application
 If the taxpayer is a dual-resident taxpayer and a long-term resident, by electing to be treated as a resident of a foreign country
for purposes of claiming benefits under an applicable income tax treaty, the taxpayer will be deemed to have expatriated pursuant to
Form  
8833
(Rev. December 2013)
Department of the Treasury  
Internal Revenue Service 
Treaty-Based Return Position Disclosure 
Under Section 6114 or 7701(b)
a
 Attach to your tax return.
a
 Information about Form 8833 and its instructions is at 
www.irs.gov/form8833
.
OMB No. 1545-1354
Attach a separate Form 8833 for each treaty-based return position taken. Failure to disclose a treaty-based return position may
 
result in a penalty of $1,000 ($10,000 in the case of a C corporation) (see section 6712). 
Name 
U.S. taxpayer identifying number 
Reference ID number, if any (see instructions)
Address in country of residence 
Address in the United States 
Check one or both of the following boxes as applicable: 
• The taxpayer is disclosing a treaty-based return position as required by section 6114 
............. 
a
• The taxpayer is a dual-resident taxpayer and is disclosing a treaty-based return position as required by 
Regulations section 301.7701(b)-7 
.............................. 
a
Note.
section 877A. For more information, see the instructions.
Check this box if the taxpayer is a U.S. citizen or resident or is incorporated in the United States 
.......... 
a
1 
Enter the specific treaty position relied on: 
a 
Treaty country 
b 
Article(s) 
2 
List the Internal Revenue Code provision(s) overruled or 
modified by the treaty-based return position 
3  
Name, identifying number (if available to the taxpayer), and 
address in the United States of the payor of the income (if 
fixed or determinable annual or periodical). See instructions. 
4 
of that article 
a
5 
Is the taxpayer disclosing a treaty-based return position for which reporting is specifically required pursuant 
to Regulations section 301.6114-1(b)?
.......................
Yes
No
If “Yes,” enter the specific subsection(s) of Regulations section 301.6114-1(b) requiring reporting
....
a
Also include the information requested in line 6. 
6 
and amount (or a reasonable estimate) of gross receipts, each separate gross payment, each separate gross income item, or 
other item (as applicable) for which the treaty benefit is claimed 
For Paperwork Reduction Act Notice, see the instructions. 
Cat. No. 14895L 
Form  
8833 
 (Rev. 12-2013) 
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