Tax Conventions with Belgium, Finland, Trinidad and Tobago, and the Netherlands: Hearings Before the ... 91-2, October 6, and November 19, 19701971 - 177 pages |
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allow a credit amount apply Article provides Belgian corporation Belgian law Belgium benefits business profits capital gains CHAIRMAN COHEN commercial profits competent authorities continental shelf death taxes decedent decedent's deduction definition dividends dividends paid domicile domiciliary double taxation Dutch effectively connected estate tax treaties exchange exempt from tax Finland Finnish tax foreign tax credit income from real income tax convention income tax treaties individual industrial or commercial interest Internal Revenue Code investment limited marital deduction Netherlands nonresident alien OECD Model Convention payments permanent establishment proposed convention contains proposed convention provides purposes rate of tax real property recent U.S. recipient reduced rate respect royalties section 351 Senator CHURCH ships or aircraft similar source country source rule subject to tax tax imposed tax laws taxable temporarily present term tion Tobago corporation transfer Trinidad and Tobago U.S. citizen U.S. corporation U.S. income tax United States tax vention withholding tax WOODWORTH worldwide estate
Popular passages
Page 101 - permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment...
Page 95 - Convention shall not be construed to restrict in any manner any exemption, deduction, credit or other allowance now or hereafter accorded, by the laws of one of the contracting States in the determination of the tax imposed by such State, or by any other agreement between the contracting States.
Page 97 - States as determined under the provisions of this part; but only in an amount which bears the same ratio to such dividends as the gross income of the corporation for such period derived from sources within the United States bears to its gross income from all sources...
Page 22 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...
Page 93 - Convention by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State concerning the taxes to which the Convention applies. Article 4. RESIDENT 1 . For the purposes of this Convention, the term "resident of a Contracting State...
Page 67 - Paragraph 1 of this Article shall not apply if the recipient of the interest, being a resident of one of the Contracting States, has a permanent establishment in the other Contracting State and the indebtedness giving rise to the interest is effectively connected with such permanent establishment.
Page 152 - ... personal services) with respect to mines, oil and gas wells and other natural deposits, the term "United States...
Page 62 - ... d) The maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or for collecting information, for the...
Page 143 - State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.
Page 69 - ... of, or of other Individuals exercising similar functions in corporations created or organized In Belgium; (b) He is temporarily present within Belgium for a period or periods not exceeding a total of one hundred eighty-three days during the calendar year and his compensation is received for labor or personal services performed as a worker or employee of, or under contract with, a resident of, or a corporation...