2026-05-30
The U.S. currently has 57 income tax treaties in effect. IRS Treaty Tables 1 and 2 each include 57 treaties. IRS Treaty Table 3 (List of Tax Treaties) has 83 lines. One line is for the Hungary treaty, which is no longer in effect. Another line is for the Russia treaty, which has been mostly suspended. Twenty-four of the lines in Table 3 refer to protocols. If you start with 83 lines, subtract two for Hungary and Russia, and then subtract 24 for protocols, the remaining 57 lines are for the treaties in effect.
The former USSR treaty applies to nine countries. The IRS Treaty Tables have a single line for these nine countries and refer to them as the “Commonwealth of Independent States.”
Qualified Dividend Income: Notice 2024-11 contains a list of 56 treaties that meet the requirements of Code §1(h)(11)(C)(i)(II) (regarding qualified dividends from foreign corporations). The treaty for the Commonwealth of Independent States is the only remaining treaty that does not satisfy the requirements of Code §1(h)(11)(C)(i)(II).
Roman numerals: Four treaties use Roman numerals for their article numbers: Canada, Greece, Pakistan, and USSR.
No titles: Five treaties have no titles / names for articles: Australia, China, Japan, Pakistan, and USSR.
IRS Website Listing of Treaties by Country:
Less former USSR republics:
Less terminated/suspended:
Total countries listed: 68
Less former USSR republics: 9
Less terminated/suspended: 2
Treaties in effect: 57