Koss, Treaty etc.

[Gretel]

Burton, I would like to ask you two questions, maybe I am just ignorant.

1. Where does it say that the treaty is for non-residents only?

2. Regardless of no. 1, my thinking is that the nature of a payment is not changed just because it crosses a border. Social Security in Germany should be Social Security in the USA, don't you agree? I did not refer to the treaty when I said the things I said.

[Koss]

Tax Treaty

The language of the treaty that was cited in the previous thread explicitly said that the provisions in question were applicable only to persons who are not US citizens or permanent residents. Right now I can't find the earlier thread. But I was simply pointing out what was in the text that had been quoted. I was not asserting that provisions of a tax treaty are never applicable to US citizens or permanent residents.

In general, I agree that the characterization of a particular type of income does not change simply because it originates in another country.

I don't have a strong opinion on this issue. To be honest, I don't remember what the original question was, except that it had to do with some sort of retirement income from Germany, and whether it would be classified as social security or a pension.

In order to form an opinion, I need to go back and read the previous thread, and maybe do some additional research.

BMK