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The competent authorities of the United States and Norway have signed an agreement under the 1970 United States - Norway income tax treaty, as amended by a 1980 protocol, clarifying the application and administration of the Treaty with respect to amounts paid to fiscally transparent entities.

The Competent Authorities of the United States and Norway hereby enter into the following mutual agreement regarding the eligibility of entities that are treated as fiscally transparent under the laws of either Contracting State to benefit under the Convention Between the United States of America and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property, signed on December 3, 1971, and as amended by the Protocol signed on September 19, 1980 (the “Treaty”).

The Competent Authorities of the USA & the Kingdom of Norway hereby enter into the following mutual agreement (the “Agreement”) clarifying the meaning of “remuneration described in Article 17 (Governmental Functions)” and “payments described in Article 19 (Social Security Payments)” as those phrases are used in the last sentence of paragraph 6 of Article 24 (Source of Income) of the Convention Between the United States of America and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property, signed on December 3, 1971, and as amended by the Protocol signed on September 19, 1980 (the ”Treaty”).

"The Truth About Frivolous Tax Arguments" addresses frivolous tax arguments in general. This document was updated March 2022

A public pronouncement containing guidance that involves substantive interpretations of the Code or other laws specific to retirement plans.

These documents are prepared by field attorneys in the Office of Chief Counsel, reviewed by an Associate Office, and subsequently issued to field or service center campus employees of the Internal Revenue Service.

Issued guidance regarding proposed procedural changes. Notices also request public comment with respect to the administration of the tax laws. The provided materials relate specifically to tax-exempt bonds.

Section III of "The Truth About Frivolous Tax Arguments" explains the penalties that the courts may impose on those who pursue tax cases on frivolous grounds. This document was updated March 2022.

These documents are prepared by field attorneys in the Office of Chief Counsel, reviewed by an Associate Office, and subsequently issued to field or service center campus employees of the Internal Revenue Service.

2007 Legal advice signed by executives in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers.