Tax Treaty

Top Tax Cases Of 2015: Bhutta v. IRS – Treaties And How They Affect Income Of Foreign Nationals

Top Tax Cases Of 2015: Bhutta v. IRS - Treaties And How They Affect Income Of Foreign Nationals

Legal System.

Issue

How can treaties between the United States and other countries affect the income of foreign nationals in the United States?

Facts

Bhutta, a citizen of Pakistan and a foreign medical school graduate, entered the United States in 2009 to participate in an internal medicine residency training program. During the three-year residency training program, for which he received an annual salary, Bhutta treated patients, with supervision; conducted and presented research; and supervised and trained third- and fourth-year medical students. His supervising and training of medical students consisted of having the medical students observe him during “rounds”, preparing the students for monthly examinations, and evaluating the students monthly.

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