conventionbetweenthegovernmentoftheunitedstatesof.PDF

CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE ITALIAN REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF FRAUD OR FISCAL EVASION The Government of the United States of America and the Government of the Italian Republic, desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and the prevention of fraud or fiscal evasion, have agreed as follows: ARTICLE 1 Personal Scope 1. Except as otherwise provided in this Convention, this Convention shall apply to persons who are residents of one or both of the Contracting States. 2. Notwithstanding any provision of this Convention except paragraph 3 of this Article, a Contracting State may tax: (a) its residents (as determined under Article 4 (Resident); and (b) its citizens by reason of citizenship as if there were no convention between the Government of the United States of America and the Government of the Italian Republic for the avoidance of double taxation with respect to taxes on income and the prevention of fraud or fiscal evasion. 3. The provisions of paragraph 2 shall not affect: (a) the benefits conferred by a Contracting State under paragraph 2 of Article 9 (Associated Enterprises), paragraphs 5 and 6 of Article 18 (Pensions, Etc.), and under Articles 23 (Relief from Double Taxation), 24 (Non-Discrimination), and 25 (Mutual Agreement Procedure); and -2- (b) the benefits conferred by a Contracting State under Articles 19 (Government Service), 20 (Professors and Teachers), 21 (Students and Trainees), and 27 (D