ARTICLE 7
U.S. Income Tax Treaty — Japan Technical Explanation - 1971 · 2026-10-03 edition · updated 2026-10-04 · United States
Nondiscrimination
The Convention bans discrimination by one State against the citizens of the other State or permanent establishments of residents of the other State (as compared with its own citizens or residents) or corporations owned by residents of the other State (as compared with corporations owned by its own residents). Thus, for example, a citizen of Japan who is a resident of the United States and who meets the requirements specified in section 911 of the Internal Revenue Code would, under this article of the Convention, be eligible for the benefits of section 911 although he is not a citizen of the United States.
This article provides, however, that a State need not accord to residents of the other State special treatment accorded to its own residents on the basis of civil status or family responsibility.
Under paragraph (3) of Article 1, the ban on discrimination extends to all taxes without regard to subject matter and whether imposed at the national, state, or local level.
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