Tax Conventions with the Philippines and France: Hearing, Ninetieth Congress, Second Session ... April 30, 1968U.S. Government Printing Office, 1968 - 72 pages |
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15 percent activities agreement ALBERT GORE American corporation apply article provides branch profits tax Brazilian CARROLL CHAIRMAN charitable commercial profits Committee competent authorities convention with France corporate tax dividend tax dividends distributed dividends paid double taxation effectively connected establishment clause exempt from tax extraterritorial foreign corporations foreign tax credit French company French corporation French subsidiary French tax French treaty Government Hearne included income from personal income tax convention income tax treaty independent agent industrial or commercial interest Internal Revenue Code investment tax nonresident OECD draft OECD model convention payments permanent establishment personal service income Philippine treaty proposed convention purpose rate of tax ratification real property resident or corporation respect royalties Senator PELL Senator SPARKMAN shareholders ship or aircraft subject to tax SURREY tax credit tax law tax on dividends taxable Thailand treaty tion Treasury treaty with Brazil treaty with France treaty with Thailand U.S. corporation withholding tax