If I am taking two treaty-based positions, do I need more than one Form 8833?
I am a French founder filing a nonresident return and my tax situation has two separate treaty arguments in play. One issue is residency under the treaty tie-breaker, and another issue is the treatment of a particular category of income. When I looked at Form 8833, I realized I may have been assuming one disclosure form covers the whole treaty universe for the year.
Before I build the return package, I want to know whether the IRS expects a separate Form 8833 for each treaty-based return position or whether multiple positions can simply be described together on one form. This feels like a technical formatting point, but in treaty work those details often become the real procedural trap.
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