Hearings, Reports and Prints of the Senate Committee on Foreign RelationsU.S. Government Printing Office, 1947 |
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1939 convention 30 percent address in France ALVORD American Chamber American citizens application article 13 article 9 assets automatic information avoidance of double Canada capital Carroll Chamber of Commerce competent authorities contracting convention with France decedent dividends domiciled in France double taxation enforcement entities estate tax evasion exchange of information exemption existing convention fiscal Foreign Trade Council French convention French general income French Government French law French tax habitual residence income tax inheritance tax Internal Revenue July 25 KING League of Nations lines of nationality memorandum mutual assistance National Foreign Trade national solidarity tax negotiations nonresident aliens October 18 paragraph person present Convention property situated proposed convention regulations request resident in France respect ROBINSON royalties schedular securities Senator SMITH Senator WHITE sources STAM Sweden tax convention tax treaty taxable taxpayer territory tion Treasury treaty United Kingdom United States citizens United States tax vention
Popular passages
Page 91 - Convention by a Contracting State any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of the Convention. ARTICLE 4 Fiscal Domicile 1. For the purposes of this Convention, the term "resident of a Contracting State...
Page 44 - In no case shall the provisions of this Article be construed so as to impose upon either of the contracting States the obligation to carry out administrative measures at variance with the regulations and practice of either contracting State...
Page 10 - State may come to an agreement with the competent authority of the other State with a view to equitable avoidance of the double taxation In question.
Page 2 - THE PRESIDENT, The White House: The undersigned, the Secretary of State, has the honor to lay before the President, with a view to its...
Page 36 - Any application shall be accompanied by documents establishing that under the laws of the state making the application the taxes have been finally determined. (4) The assistance provided for in this article shall not be accorded with respect to the citizens, corporations, or other entities of the state to which application is made...
Page 142 - America shall forward to the competent authorities of Canada as soon as practicable after the close of each calendar year the following information relating to such calendar year: The names and addresses of all persons whose addresses are within Canada and who derive from sources within the United States of America dividends, interest, rents, royalties, salaries, wages, pensions, annuities, or other fixed or determinable annual or periodical profits and Income, showing the amount of such profits...
Page 130 - (1) The taxation authorities of the Contracting Parties shall exchange such information (being information available under the respective taxation laws of the Contracting Parties) as is necessary for carrying out the provisions of the present Convention...
Page 143 - Convention or for the prevention of fraud or the administration of statutory provisions against legal avoidance in relation to the taxes which are the subject 6f the present Convention.
Page 136 - State, or (2) to supply particulars which are not procurable under its own legislation or that of the State making application.
Page 73 - States which have been finally determined may be accepted for enforcement by the other Contracting State and collected in that State in accordance with the laws applicable to the enforcement and collection of its own taxes. The State to which application is made shall not be required to enforce executory measures for which there is no provision in the law of the State making the application.