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Article 24 is not subject to the saving clause of subparagraph 4(a) of Article 1 (General

U.S. Income Tax Treaty — Technical Explanation - 2003 · 2026-10-03 edition · updated 2026-10-04 · United States

Scope) by virtue of the exceptions in paragraph 5 of that Article. Thus, for example, a U.S. citizen who is a resident of Japan may claim benefits in the United States under this Article.

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Nationals of a Contracting State may claim the benefits of paragraph 1 regardless of whether they are entitled to benefits under Article 22 (Limitation on Benefits), because that paragraph applies to nationals and not residents. They may not claim the benefits of the other paragraphs of this Article with respect to an item of income unless they are generally entitled to treaty benefits with respect to that income under a provision of Article 22.

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