Tax Treaties with the United Kingdom, the Republic of Korea, and the Republic of the Philippines: Hearings Before the Committee on Foreign Relations, United States Senate, Ninety-fifth Congress, First Session ... July 19 and 20, 1977U.S. Government Printing Office, 1977 - 496 pages |
Other editions - View all
Common terms and phrases
actor administrative Advance Corporation Tax affiliates airlines allocation American amount apply arm's length Article 9 Article 9(4 article XI ASARCO Bank benefits British business profits Chairman citizen combined reporting Committee companies Contracting corporate tax determining dividends double taxation earnings effect enterprise Federal foreign corporations Foreign Relations foreign source income foreign tax credit Franchise Tax Board Government income tax treaty interest Internal Revenue Code Internal Revenue Service investment John Sparkman legislation limited ment multinational corporations negotiations operations paragraph parent payments percent permanent establishment personal services Philippine proposed treaty ratification refund resident respect royalties rules Section 482 Senator CHURCH Senator Lucas statement subsidiary tax authorities tax liability tax system taxable taxpayer tion U.K. corporation U.K. treaty U.S. Senate U.S. shareholders U.S. tax unitary apportionment unitary business unitary concept unitary formula unitary method unitary system unitary tax United Kingdom United States tax withholding tax WOODWORTH worldwide
Popular passages
Page 347 - ... in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
Page 460 - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests...
Page 387 - Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment...
Page 203 - It is quite apparent that if, in the maintenance of our international relations, embarrassment — perhaps serious embarrassment — is to be avoided and success for our aims achieved, congressional legislation which is to be made effective through negotiation and inquiry within the international field must often accord to the President a degree of discretion and freedom from statutory restriction which would not be admissible were domestic affairs alone involved.
Page 195 - The broad statement that the federal government can exercise no powers except those specifically enumerated in the Constitution, and such implied powers as are necessary and proper to carry into effect the enumerated powers, is categorically true only in respect of our internal affairs. In that field, the primary purpose of the Constitution was to carve from the general mass of legislative powers then possessed by the states such portions as it was thought desirable to vest in the federal government,...
Page 155 - Business income" means income arising from transactions and activity in the regular course of the taxpayer's trade or business and includes income from tangible and intangible property if the acquisition, management, and disposition of the property constitute integral parts of the taxpayer's regular trade or business operations. (b) "Commercial domicile" means the principal place from which the trade or business of the taxpayer is directed or managed.
Page 398 - ... commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
Page 369 - In accordance with the provisions and subject to the limitations of the law of the United States (as it may be amended from time to time without changing the general principle hereof...
Page 220 - State, the taxpayer may petition for or the tax administrator may require, in respect to all or any part of the taxpayer's business activity, if reasonable: (a) separate accounting; (b) the exclusion of any one or more of the factors...
Page 203 - The nature of foreign negotiations requires caution ; and their success must often depend on secrecy ; and, even when brought to a conclusion, a full disclosure of all the measures, demands, or eventual concessions which may have been proposed or contemplated would be extremely impolitic ; for this might have a pernicious influence on future negotiations, or produce immediate inconveniences, perhaps danger and mischief, in relation to other powers.