Ireland/U.S. DTA, 1949 - Article XVIII
29/11/1996
Query
Ireland/U.S. Double Taxation Convention - Article XVIII - Professors and Teachers - question of treatment of the exemption from income tax provided for in Article XVIII in cases where the 2 year time limit is exceeded.
Decision
In accordance with the U.S. practice the Revenue Commissioners will not seek to tax the income retroactively where the stay exceeds 2 years
Income Tax
Schedule 25, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:DTX 7081/96