Most Russian double taxation treaties contain provisions regarding the following elements that make up taxable income, such as: the president said in his speech that “all income payments (in the form of interest and dividends) paid from Russia to offshore lawyers must be properly taxed.” It is therefore proposed that “. For those who pay their dividends from the country to foreign accounts, the tax rate on these dividends should be set at 15%. “Second, the United States authorizes a foreign tax credit to deduct income tax paid to foreign countries from U.S. income tax due on foreign income that is not covered by this exclusion. The foreign tax credit is not allowed for taxes paid on business income excluded by the rules described in the previous paragraph (for example, no double dive).  (For a transitional period, some states have a separate regime.[ 8] You can offer any non-resident account holder the choice of tax modalities: either (a) disclosure of the information mentioned above, or (b) deduction at source of local tax on savings income, as is the case for residents). In principle, U.S. citizens are taxable on their global income, wherever they live. However, some measures mitigate the resulting double taxation obligation.
 In an address to the nation on March 25, 2020, the Russian president announced a series of tax initiatives, one of which concerns the taxation of dividends from Russia, that could have a significant impact on the tax treaty system. Most tax systems attempt to have an integrated system using different tax rates and tax credits, in which income earned by a company and paid out as dividends and income directly received by a person end up being taxed at the same rate. For example, in the United States, dividends that meet certain criteria may be considered “qualified” and, as such, subject to tax remuneration: a tax rate of 0%, 15% or 20%, depending on the tax bracket of the person. The corporate tax rate will be 21% from 2019. To avoid these problems, countries around the world have signed hundreds of contracts to avoid double taxation, often based on models from the Organisation for Economic Co-operation and Development (OECD). In these agreements, the signatory states agree to limit their taxation of international transactions in order to promote trade between the two countries and avoid double taxation. Preferential taxation applies to institutional investments as well as to listed companies that, during the year, hold at least 15% of the shares and hold at least 15% of the share capital in the company paying this income. The exemptions also apply to income received by these companies on interest on bank loans, outstanding Eurobond loans, as well as on bonds issued by governments, central banks, pension funds and insurance companies of the countries participating in the agreement. 18 The revised double taxation agreement between India and Cyprus, signed on 27 November 2016, provides for source-based taxation on capital gains from the sale of shares instead of the residence-based taxation provided for under the double taxation convention signed in 1994. . .