Proposed Income Tax Convention Between the United States and Iceland: Prepared for the Use of ... by the Staff of the Joint Committee on Internal Revenue Taxation, November 4, 1975 |
Common terms and phrases
business profits provisions capital gains contains a provision continental shelf coun country for 183 country is exempt dividends are effectively dividends paid double taxation exempt from tax exploitation of natural fixed base foreign tax credit holding companies host country Icelandic corporation income derived income from sources income tax convention income tax treaties independent personal services individual is present interest is effectively Internal Revenue Code international traffic investment or holding natural resources nected OECD model convention operation in international passive income permanent estab permanent establishment profits provisions Article proposed convention contains proposed convention follows proposed convention provides rate of tax real property recent U.S. income recent U.S. tax related person resident of Iceland ship or aircraft Shipping and air source country unless source of income STANFORD UNIVERSITY tax benefits tax unless effectively taxable tion traffic of ships Trinidad and Tobago U.S. citizen U.S. income tax U.S. tax treaties unless the recipient
Popular passages
Page 1 - In addition, a similar provision was added to the Internal Revenue Code by the Tax Reform Act of 1969. (2...
Page 5 - State be attributed to the permanent establishment the industrial or commercial profits which would reasonably be expected to have been derived by it if it were an independent entity engaged in the same or similar activities under the same or similar conditions and dealing at arm's length with the resident of which it is a permanent establishment.
Page 2 - Act of 1969) except that under the Code the continental shelf definitions apply only with respect to mines, oil and gas wells, and other natural deposits. Under the proposed convention, the applicability of the definition is not...
Page 7 - The reduced rates of tax on dividends will apply unless the recipient has a permanent establishment in the source country and the dividends are effectively connected with the permanent establishment.
Page 3 - An individual whom both countries consider to be a resident according to their general rules for determining residence will be deemed for all purposes of the convention to be a resident of the country in which he has his permanent home (where an individual dwells with his family), his center of vital interests (his closest economic and personal relations), his habitual abode, or his citizenship.
Page 1 - ... income is not effectively connected with the permanent establishment. Other important features of the proposed convention include the following: (1) The United States and Poland are defined to include their respective continental shelves for purposes of taxing income arising from the exploration and exploitation of natural resources on the continental shelf. The effect of this provision is to recognize a country's jurisdiction to tax income arising in connection with natural resource activities...
Page 10 - In addition to the exemption regarding students, the proposed convention follows the approach of other recent US tax treaties and provides a limited exemption for personal service income of residents of one country who are employees of a resident of that country and who are temporarily present in the other country to study at. an educational institution or acquire technical, professional or business experience.
Page 1 - This feature is embodied in The Foreign Investors Tax Act of 1966 and other recent US tax treaties. The other more important features of the proposed convention are the following : (1) The United States and...
Page 4 - Industrial or commercial profits attributable to a permanent establishment will be considered to be from sources within the country in which the permanent establishment is located. This rule also applies to passive income of the types described above in situations where the passive income is treated as industrial or commercial profits because it is effectively connected with the permanent establishment. The source of any item of income not specified in...
Page 5 - State in which the permanent establishment is situated or elsewhere. (4) No profits shall be attributed to a permanent establishment merely by reason of the purchase of goods or merchandise by that permanent establishment, or by the resident of which it is a permanent establishment, for the account of that resident. (5) The term "industrial or commercial profits...