Irc Section 6114

6114 a in general each taxpayer who with respect to any tax imposed by this title takes the position that a treaty of the united states overrules or otherwise modifies an internal revenue law of the united states shall disclose in such manner as the secretary may prescribe such position i r c. Regulations section 301 6114 1 c waives reporting on a form 8833 for certain treaty based return positions. 301 6114 1 b 8 1 c 2 clause 2 301 7701 b 7 b c was the position that a treaty reduces or modifies the taxation of income derived from dependent personal services pensions annuities social security and other public pensions or income derived by artistes athletes students trainees or teachers.

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