Taxes in the Bahamas: what US expats need to know
The Bahamas does not levy a broad personal income tax. A US citizen living there still reports worldwide income to the IRS and may need Form 1040, Form 2555, FinCEN Form 114, or Form 8938 for the 2025 tax year.
A US expat in Nassau may owe no Bahamian tax on salary yet still face VAT, property, or business charges locally and US reporting.
US citizens and resident aliens abroad remain subject to US filing rules, while TFX’s US expat tax guide explains the filing framework.
The following 3 points give the fastest view of taxation in the Bahamas for an American resident or investor:
- Who pays locally: consumers, property owners, importers, and businesses can owe tax or fees.
- Taxes that matter most: VAT, real property tax, customs duties, and business licence tax.
- What Americans still file: TFX’s guide to US citizens living abroad covers Form 1040 and related forms such as Form 2555, FBAR, or Form 8938.
Before relocating, also review the State Department’s current Bahamas information for entry and local-law basics.
Key takeaways
For the 2025 tax year, Americans in the Bahamas can face 2 tax systems even without Bahamian personal income tax. The local focus is usually VAT, property, customs, and business charges, while US citizens generally continue filing on worldwide income. IRS FEIE rules may reduce US income tax.
The following 6 points cover the rules most likely to affect an American household, worker, investor, or business owner:
- No broad local personal income tax: salary and investment income are not subject to a general Bahamian individual income tax.
- US filing continues: US citizens and resident aliens abroad generally report worldwide income on Form 1040.
- FEIE may help: the 2025 maximum exclusion is $130,000 per qualifying person.
- No bilateral income tax treaty: the US and Bahamas do not have one that provides ordinary treaty relief.
- No totalization agreement: US self-employment tax and Bahamian social insurance rules must be reviewed separately.
- Other local taxes still apply: property tax, 10% VAT on most taxable supplies, customs duties, and business licence tax can matter.
See TFX’s Foreign Earned Income Exclusion guide for Form 2555 rules. For social-insurance coordination, our totalization agreement guide explains what these agreements normally do and why their absence matters here.
How Bahamas taxation works in practice
Taxation in the Bahamas works through spending, property, imports, and business, not broad individual income tax. In 2026, Bahamas taxation includes 10% standard VAT, property tax bands, customs charges, and turnover-based business licence rules.
Citizenship-based taxation remains a separate US issue.
The Bahamas tax system can still reach a household through spending or ownership even when wages have no local income tax in the Bahamas.
Bahamas tax laws also apply to businesses, imports, and property, so “no income tax” does not mean “no local tax.”
The following 4-step flow shows where local liability can arise:
- Spend locally → VAT may be included in the price.
- Own real estate → real property tax may apply by classification and value.
- Import goods → customs duty may apply by tariff classification.
- Operate a business → licensing, turnover tax, VAT, and recordkeeping may apply.
The key rule is that 4 different triggers – spending, property, imports, and business activity – can create local tax even when personal income tax is 0%.
| Tax type | Who pays it | Trigger | Example |
|---|---|---|---|
| VAT | Consumers; registered businesses collect it | Taxable purchase or supply | Restaurant meal |
| Real property tax | Property owners | Owning taxable Bahamian real estate | Nassau residence |
| Customs duties | Importers | Bringing dutiable goods into the Bahamas | Shipped furniture |
| Business licence tax | Businesses | Carrying on business and applicable turnover | Local consulting activity |
Bahamas tax rates at a glance
The headline 0% personal income tax rate does not make daily life tax-free. As of September 2026, the standard VAT rate is 10%, real property tax varies by classification and value, and general business licence tax tops out at 1.25% on turnover above $5 million.
The 2026 snapshot below separates the 0% broad individual income-tax rate from taxes tied to spending, property, imports, and business turnover.
| Tax | Current rule | Who should care |
|---|---|---|
| Broad personal income tax | 0% | Employees, retirees, investors |
| VAT | 10% standard rate; exemptions and zero-rating exist | Consumers and businesses |
| Real property tax | Rate depends on property class and assessed value | Property owners |
| Customs duty | Varies by tariff classification and relief | Importers and movers |
| Business licence tax | General turnover bands from 0.5% to 1.25%, topping out at 1.25% for turnover above $5 million | Business owners |
The local snapshot should be read with your US filing position. TFX’s document checklist for countries with no personal income tax shows what records US filers still need. This Bahamas tax guide keeps the local and US rules together.
Who actually pays taxation in the Bahamas
Local exposure depends on what you do in the Bahamas, not only where you live. In 2026, 5 common groups can face tax or filing duties: residents, non-residents, property owners, business owners, and importers. US status creates a separate federal filing layer.
The following 5 categories show the main local triggers:
- Residents: usually pay VAT through spending and may owe property or business charges.
- Non-residents: can owe tax through Bahamian property, business, or taxable purchases.
- Property owners: may owe real property tax based on classification and assessed value.
- Business owners: can face licence, VAT, and recordkeeping duties.
- Importers: can owe customs duty and import VAT depending on the goods and relief available.
If this is you: residence alone does not create a broad personal income tax, but ownership, spending, importing, or carrying on business can create local obligations.
The practical distinction is activity-based: 1 non-resident property owner can have local tax exposure even when a resident employee owes no Bahamian tax on salary.
| Profile | VAT | Property tax | Business licence | Customs |
|---|---|---|---|---|
| Resident employee | Through purchases | If owner | Usually no | If importing |
| Resident freelancer | Through purchases; registration may apply | If owner | May apply | If importing |
| Non-resident owner | Through purchases | May apply | If carrying on business | If importing |
| Visitor | Through purchases | Usually no | Usually no | If importing goods |
TFX’s resident and non-resident tax guide explains why tax residence, citizenship, and source rules should not be treated as the same concept.
Residents
A Bahamas resident can encounter local tax without paying a broad income tax on salary. In 2026, the practical checks are VAT at 10% on most taxable supplies, real property tax if you own taxable property, and business licensing if you carry on a business locally.
The following 3 checks cover the most common resident obligations:
- Everyday spending: expect VAT on most taxable goods and services.
- Property ownership: check the real property classification and assessed value.
- Self-employment or business: check business licence and VAT registration rules.
A salaried household in Nassau may mainly see VAT and property tax.
A resident freelancer can add business licence, VAT, and recordkeeping duties even when personal earnings are not subject to local income tax.
Residence for US tax benefits is a different test.
Review TFX’s bona fide residence test guide and domicile versus residence guide before assuming a Bahamian immigration status satisfies Form 2555.
Non-residents
A non-resident can still owe local tax through property, business, imports, or taxable purchases. In 2026, foreign ownership can affect property classification, and a foreign owner-occupied category took effect July 1, 2026 for qualifying non-Bahamian permit holders who use the property as a home.
The main difference is that local tax exposure can follow the asset or activity even when a person spends 0 days as a tax resident under a separate residence analysis.
| Issue | Resident | Non-resident |
|---|---|---|
| VAT on local purchases | Yes | Yes |
| Real property tax | If taxable property is owned | If taxable property is owned |
| Business licence | If carrying on a covered business | If carrying on a covered business |
| Broad personal income tax | No | No |
Buying property abroad also creates US reporting and recordkeeping questions. TFX’s guide to buying foreign real estate covers the US-side issues that can arise before and after a purchase.
The reality of Bahamas income tax for Americans abroad
Income tax in Bahamas is not a broad local tax on individual wages, but US citizens generally remain taxable by the United States on worldwide income. For 2025, the Bahamas income tax rate on ordinary personal earnings is 0%, while federal US rules still apply.
This is why calling the Bahamas tax free is incomplete.
For personal earnings, the tax rate Bahamas residents face locally is 0%, but VAT, property, customs, business charges, and US tax can still apply.
Do wages become tax-free for a US citizen?
No. Taxes in the Bahamas for US citizens do not replace Form 1040, although Form 2555 or other US provisions may reduce federal income tax.
What about self-employment income?
The Bahamas does not impose a broad personal income tax on that profit, but local business rules can apply. US self-employment tax can also remain due even when FEIE applies.
What about investment income?
The Bahamas generally does not impose a broad individual income tax on dividends or capital gains, but US federal tax and reporting can still apply.
For 2025, the local 0% broad personal-income rate does not remove US tax on wages, self-employment profit, dividends, interest, or gains.
| Income type | Taxed by Bahamas as broad personal income tax? | Taxed or reportable by US? |
|---|---|---|
| Wages | No | Generally yes; FEIE may apply |
| Self-employment profit | No broad income tax | Generally yes; SE tax can apply |
| Interest/dividends | No broad individual income tax | Generally yes |
| Capital gains | No general individual capital gains tax | Generally yes |
No treaty, no totalization agreement
The US and Bahamas have no bilateral income tax treaty and no Social Security totalization agreement As of September, 2026. A Bahama tax haven label does not change that. Tax-information exchange arrangements exist, but they do not provide ordinary treaty relief or coordinate payroll taxes.
The following 3 protections are not available through a US-Bahamas income tax treaty or totalization agreement:
- Income-tax treaty relief: no treaty articles allocate ordinary pension, wage, or investment taxing rights.
- Social Security coordination: no totalization agreement prevents dual coverage by treaty rule.
- Treaty residence tie-breakers: no bilateral income-tax residence article is available.
TFX’s US tax treaty guide explains what income tax treaties can do.
The SSA list of international Social Security agreements does not include the Bahamas, so self-employed Americans should review US Schedule SE and Bahamian social-insurance rules separately.
What this means for you: review US reporting, FEIE, foreign tax credits, and payroll obligations independently instead of assuming treaty relief.
Other Bahamas taxes that still matter
Bahamas taxes still reach spending, property, imports, and businesses even with a 0% broad personal income-tax rate. In 2026, the Bahamas tax rate you face depends on the transaction: VAT is usually 10%, while property, customs, and business licence charges use separate rules.
The following 4 local taxes or charges deserve a separate check:
- Real property tax: based on property category and assessed value.
- VAT: 10% standard rate on most taxable supplies, subject to exemptions and zero-rating.
- Customs duties: vary by tariff classification and relief.
- Business licence tax: can depend on turnover and business type.
A company may also fall within newer corporate-level rules that do not apply to a typical individual expat.
TFX’s foreign business structure guide explains why US entity reporting should be checked separately from local licensing.
Property tax and Bahamas real property tax bands
Bahamas real property tax depends on class and value. In 2026, Bahama tax rates cover 5 broad categories, including owner-occupied, residential, commercial or rental, vacant-land, and foreign owner-occupied property. The last category applies from July 1, 2026 to qualifying non-Bahamian owners.
For 2026, foreign owner-occupied property is taxed at a flat 0.625% of assessed value, capped at $200,000 annually – there is no separate rate tier above $1 million.
| Property category | 2026 rate or band | Key point |
|---|---|---|
| Owner-occupied | First $300,000 exempt; next $200,000 at 0.625%; balance over $500,000 at 1% | Annual cap is $150,000 under 2026 amendment |
| Foreign owner-occupied | Flat 0.625% of assessed value | New from July 1, 2026; annual cap $200,000 |
| Residential, up to 4 units | Up to $75,000: $300 flat; excess at 0.625% | Classification matters |
| Commercial or foreign-owned rental | First $500,000 at 0.75%; next $1.5 million at 1%; balance at 1.5% | Commercial/foreign rental category |
| Vacant land for foreigners | First $7,000: $100; balance at 2% | Foreign-owned vacant land |
A primary home, rental property, and vacant land can fall into different bands.
Before buying, confirm the classification and current assessment with the Department of Inland Revenue.
The IRS rules for US real estate tax deductions explain when property tax can qualify for a US itemized deduction.
That US rule does not determine the Bahamian rate or property category.
VAT and everyday spending
VAT is a consumption tax, and the standard Bahamas rate is 10% in 2026. Consumers pay it on most taxable goods and services. From April 1, 2026, a new amendment exempted listed qualifying unprepared food items sold by food stores.
Four everyday purchases show where VAT can appear: a restaurant meal, hotel service, household goods, and professional services.
The exact treatment depends on whether the supply is standard-rated, zero-rated, or exempt.
The following 3 situations matter most:
- Visitors: pay VAT on taxable local purchases.
- Residents: pay VAT through normal household spending.
- Businesses: registration is generally mandatory when taxable activity exceeds $100,000 over the relevant 12-month test.
Based on our client scenario at TFX: a taxable service priced at $200 before VAT produces $20 of VAT at 10%, for a $220 total.
Retail pricing rules can require VAT-inclusive display, so the receipt may show the tax inside the final price.
Customs duties
Customs duties apply to imported goods according to the tariff and available exemptions. In 2026, a move to the Bahamas can create charges even when personal income tax is 0%, so classify goods before shipping rather than assuming imports are duty-free.
The following 3 import situations need different checks:
- Personal effects: relief can depend on the item and eligibility.
- Shipped household goods: tariff classification and import rules can apply.
- Business inventory: customs duty, import VAT, and business records may all matter.
A newcomer can be surprised by import costs on furniture, vehicles, or commercial stock.TFX’s year-end financial checklist for expats can help organize records. Our moving abroad checklist covers practical pre-move documentation.
Does the Bahamas tax self-employment, capital gains, inheritance, or wealth?
The Bahamas has no 1 broad personal income-tax system that separately taxes these categories. As of September, 2026, self-employment can trigger business rules, while capital gains, inheritance, wealth, and gifts need transaction-specific checks instead of one tax-rate assumption.
The following 5 myth-and-fact points separate income tax from other obligations:
- Self-employment: no broad personal income tax, but business licence, VAT, National Insurance, and US self-employment tax can apply.
- Capital gains: no general individual capital gains tax, but property transfers and US capital gains rules can still matter.
- Inheritance: no general inheritance or estate tax, but estate administration and US transfer-tax rules can still apply.
- Wealth tax: there is no general annual net-wealth tax; real property tax is separate.
- Gifts: there is no general individual gift tax, but property-transfer rules and US gift reporting can apply.
For US freelancers, TFX’s self-employed expat tax guide covers Schedule C, Schedule SE, FEIE, and related US filing issues.
The takeaway for US expats is simple: local income-tax neutrality does not remove US tax or Bahamian transaction, property, business, or consumption taxes.
Business licence fees and company-level rules
A person carrying on business in the Bahamas generally needs to check licensing even when no broad personal income tax applies. For 2026, turnover of $50,000 or less carries a flat $100 fee, then the rate is 0.5% on turnover from $50,001 to $500,000. The rate rises to 0.75% on turnover from $500,001 to $5 million and 1.25% above $5 million – the top general rate, with no additional band above that.
The following 3 business profiles can face different rules:
- Sole proprietors: licensing, turnover tax, VAT, and National Insurance can apply.
- Local companies: entity-level licensing, VAT, accounting, and corporate rules can apply.
- Foreign-owned businesses: licensing and US international information returns may also need review.
For general businesses without a special schedule, the bands are 0.5% on turnover from $50,001 to $500,000 and 0.75% on turnover from $500,001 to $5 million.
A separate Domestic Minimum Top-Up Tax can apply to Bahamian entities in MNE groups with at least €750 million in annual global revenue.
A 2026 amendment took effect July 1, 2026 and updated filing and GloBE-rule provisions.
The following 3 compliance steps apply to an annual licence under the general timetable:
- Renew: submit the renewal application by January 31.
- Report and settle: file prior-year turnover and unpaid prior-year tax by March 31.
- Pay estimated tax: pay by March 31 or, if approved, in 4 installments through December 31.
A freelancer and storefront can both be businesses, but their turnover, VAT status, premises, and regulatory approvals can differ.
The offshore corporation guide covers US reporting considerations for foreign entities.
The IRS small-business resources cover US federal obligations that may apply alongside Bahamian rules.
Business Licence Act records are generally kept for 5 years. VAT records also have a 5-year retention rule. Keep ledgers, invoices, bank statements, and customs documents in a retrievable file.
Tax authorities, compliance, and dispute process in the Bahamas
The Bahamas Department of Inland Revenue administers VAT, Business Licence, and Real Property Tax. In 2026, records can have 5-year retention periods, while objections to certain property or business assessments generally start with a 30-calendar-day window after notice.
The following 4 steps are a practical compliance sequence:
- Register: obtain the required TIN, VAT registration, business licence, or property account.
- File and pay: follow the return and payment dates for the specific tax.
- Keep records: retain supporting invoices, ledgers, bank records, and assessment notices.
- Object or appeal: use the tax-specific objection process before the deadline expires.
For VAT, returns are generally due within 21 days after the tax period.
For annual business licences, renewal is due January 31 and prior-year turnover reporting is due March 31.
The following 5 records are useful when a notice or assessment arrives:
- Filed returns and confirmations
- Invoices and receipts
- Bank statements and payment proof
- Property assessments or conveyance records
- Correspondence with the Department of Inland Revenue
TFX’s tax record-retention guide explains US recordkeeping alongside local files.
If a notice arrives, our guide to responding to an IRS letter shows how to separate a US notice from a Bahamian assessment.
For a 2026 real property assessment, the statute counts 30 calendar days from service of the notice, subject to limited late-objection relief.
Professional local help is advisable when you receive an assessment, penalty, lien notice, or disputed classification.
Bahamian procedural deadlines and evidence rules can control the next step.
US deadlines and forms: taxes in the Bahamas for US citizens do not end locally
For a 2025 US return filed in 2026, Americans abroad generally use Form 1040 and may need Form 2555, Form 1116, FBAR, or Form 8938. The regular payment deadline was April 15, 2026, while qualifying taxpayers abroad received an automatic filing extension to June 15.
The main 2026 filing dates are April 15 for payment, June 15 for the automatic overseas filing extension, and October 15 for a timely Form 4868 extension.
| Form | Main purpose | 2025 return trigger or deadline |
|---|---|---|
| Form 1040 | US individual income tax return | Worldwide-income filing rules apply |
| Form 2555 | FEIE and foreign housing exclusion/deduction | File with Form 1040 when claiming section 911 benefits |
| Form 1116 | Foreign Tax Credit | Eligible foreign income tax on foreign-source income |
| FinCEN Form 114 | FBAR | Aggregate foreign accounts over $10,000; due April 15, automatic to October 15 |
| Form 8938 | Specified foreign financial assets | Abroad: over $200,000 year-end/$300,000 anytime single; $400,000/$600,000 joint |
The expat IRS form checklist helps map income and assets to forms. Compare FBAR with FATCA in TFX’s FBAR versus FATCA guide. The $10,000 FBAR threshold and Form 8938 thresholds are not interchangeable.
What must I file?
Start with Form 1040 if you meet the US filing threshold, then add forms based on foreign earned income, taxes paid, account balances, foreign assets, entities, and investments.
A 2026 filing-season change can also affect 2025 returns: Schedule 1-A is used for new deductions for qualified tips, overtime, certain vehicle-loan interest, and an additional senior deduction.
Eligibility is rule-specific and is not created by living abroad.
NOTE! If you have lived abroad for several years and only recently learned about US filing or FBAR requirements, filing the current year alone may not address earlier gaps. Eligible taxpayers whose prior failures were non-willful may need to consider the IRS Streamlined Filing Compliance Procedures.
Tax planning tools for Americans abroad
For the 2025 tax year, 3 core US tools can matter in the Bahamas: the $130,000 FEIE, foreign housing exclusion or deduction, and Foreign Tax Credit. The best fit depends on income type, foreign taxes paid, qualifying days, and housing costs.
In a 0% broad personal-income-tax jurisdiction, FEIE and housing benefits can be more useful than an FTC when no creditable foreign income tax was paid.
| Tool | 2025 anchor | When it can help |
|---|---|---|
| FEIE | Up to $130,000 per qualifying person | Foreign earned income |
| Foreign housing exclusion/deduction | $20,800 base; Nassau limit $49,700 | Qualified foreign housing costs |
| Foreign Tax Credit | Credit limited by eligible foreign income taxes | Income taxed by a foreign country |
The Foreign Tax Credit guide covers Form 1116 mechanics.
The IRS Foreign Tax Credit rules explain that the credit generally applies to qualifying foreign income taxes, not VAT, customs duty, or real property tax.
Foreign Earned Income Exclusion
The FEIE can exclude up to $130,000 of qualifying foreign earned income per person for the 2025 tax year. To claim it, you need a foreign tax home plus either the bona fide residence test or 330-full-day physical presence test, and you file Form 2555.
The following 3 records help support a 2025 Form 2555 claim:
- Day-count evidence: passports, travel records, and calendars.
- Tax-home facts: work location and facts showing your regular place of business.
- Income records: pay statements, contracts, and self-employment records for services performed abroad.
A Bahamas employee can use FEIE on qualifying wages if the tests are met.
A self-employed contractor can use FEIE on qualifying earned income, but the exclusion does not reduce US self-employment tax.
See TFX’s physical presence test guide for the 330-day rule and travel-day treatment.
Housing exclusion
For 2025, the foreign housing calculation starts with qualified housing expenses and subtracts a $20,800 base amount. The general expense cap is $39,000, but Nassau has a higher 2025 location limit of $49,700, so Form 2555 can produce a larger amount.
The following 5 common expense categories can qualify when they meet IRS rules:
- Rent
- Utilities other than telephone charges
- Residential parking
- Occupancy taxes
- Certain household repairs and insurance
Home purchase costs, furniture purchases, domestic labor, and lavish or extravagant expenses are not qualifying housing expenses.
Based on our client scenario at TFX: a Nassau employee has $55,000 of qualifying 2025 housing costs.
The $49,700 Nassau cap limits expenses; then the $20,800 base is subtracted, leaving a potential $28,900 housing amount before other Form 2555 limits.
The 2026 IRS location limit for Nassau is also $49,700.
Notice 2026-25 allows a higher 2026 location limit to be used for 2025 when it is higher, but Nassau’s unchanged limit provides no increase.
Read TFX’s foreign housing exclusion guide for the calculation.
If education aid is relevant, our FEIE and FAFSA guide explains how excluded income can matter outside the income-tax calculation.
Why the foreign tax credit is usually limited here
The Foreign Tax Credit is usually limited in the Bahamas because there is no broad Bahamian personal income tax to credit against US tax. For 2025, Form 1116 generally requires eligible foreign income tax, so 10% VAT or real property tax does not substitute for income tax.
The following 3 situations show where the FTC can and cannot help:
- Foreign income-tax withholding elsewhere: it can potentially generate credit if the tax is eligible and properly sourced.
- Bahamian VAT or customs duty: these are not foreign income taxes for Form 1116.
- Bahamian real property tax: it is not an income tax for the FTC.
The decision rule is simple: FEIE targets qualifying earned income up to $130,000 for 2025, while FTC depends on eligible foreign income tax actually paid or accrued.
| Tool | Main input | Typical Bahamas issue |
|---|---|---|
| FEIE | Qualifying foreign earned income and section 911 tests | Often relevant to employees and freelancers |
| FTC | Creditable foreign income tax | Often limited when no Bahamian income tax was paid |
TFX’s FEIE versus Foreign Tax Credit guide explains why the same income cannot receive duplicated tax benefits.
Bahamas real estate and the foreign income exclusion
Owning Bahamas real estate does not make rental income or a property gain eligible for FEIE. For 2025, Form 2555 covers qualifying earned income from services, not passive rent or capital gains. Property ownership can also create Bahamian tax and separate US reporting.
The 3 common real-estate uses below have different US results, and only service income can qualify for FEIE.
| Property use | Bahamas issue | US consequence |
|---|---|---|
| Live-in home | Real property tax may apply | Personal property; sale rules can apply |
| Rental property | Property tax and local compliance may apply | Rental income generally reported on Schedule E |
| Vacant land | Property tax classification can apply | Gain on sale generally remains reportable |
See TFX’s foreign rental income guide for Schedule E treatment.
If you sell, our foreign property capital gains guide explains the US gain calculation and foreign-property issues.
The IRS rental real estate rules cover income and deductible rental expenses.
A foreign property can also create entity, account, or asset reporting if held through a foreign company, trust, partnership, or financial account.
FAQs on taxes in the Bahamas for US citizens
Americans can pay VAT, real property tax, customs duties, and business licence tax in the Bahamas.
A US citizen also generally reports worldwide income to the IRS even when no broad Bahamian personal income tax is due.
The Bahamas does not levy a broad personal income tax on individuals As of September, 2026.
Separate taxes can still apply to property, consumption, imports, business activity, and certain corporate groups.
For 2025, a qualifying person can exclude up to $130,000 of foreign earned income on Form 2555.
You must have a foreign tax home and meet either the bona fide residence or physical presence test.
Yes, the standard VAT rate is 10% on most taxable goods and services.
From April 1, 2026, listed qualifying unprepared food items sold by food stores became exempt under the 2026 VAT amendment.
Potentially. Real property tax depends on the property’s classification and assessed value.
From July 1, 2026, the law added a foreign owner-occupied category for qualifying non-Bahamian permit holders.
There is no US-Bahamas income tax treaty and no Social Security totalization agreement As of September, 2026.
Tax-information exchange and FATCA arrangements are separate and do not supply ordinary income-tax treaty benefits.
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