Legislative History of United States Tax ConventionsU.S. Government Printing Office, 1962 - 4704 pages |
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Common terms and phrases
85th Congress amended apply approval Australia avoidance of double Belgian Belgium British Canadian CARROLL CHAIRMAN citizens Committee on Foreign Cong Congress convention and protocol dividends Doctor ADAMS domiciled double taxation effect enterprise entity estate tax Etats contractants Etats-Unis exchange Executive existing convention Finland fiscal evasion foreign country Foreign Relations foreign tax France French GARNER Government income tax income-tax convention instruments of ratification interest Internal Revenue Code KING licensor ment negotiated nonresident alien Norway October 28 Pakistan paragraph pending convention percent permanent establishment present Convention prevention of fiscal principle profits question real property reciprocal exemption rentals resident or corporation respect to taxes royalties Ruanda-Urundi Secretary Senator GEORGE Senator SMITH sess session signed at Washington South Africa STAM supplementary convention supplementary protocol tax conventions tax imposed tax treaties taxable taxes on income taxpayer territories tion trade or business United Kingdom United States tax vention
Popular passages
Page 546 - Our constitution declares a treaty to be the law of the land. It Is consequently to be regarded in courts of justice as equivalent to an act of the legislature whenever it operates of itself, without the aid of any legislative provision ; but when the terms of the stipulation import a contract, when either of the parties engages to perform a particular act, the treaty addresses itself to the political, not the judicial, department; and the legislature must execute the contract before it can become...
Page 397 - Mr. President, I ask unanimous consent that the order for the quorum call be rescinded.
Page 242 - ... by the United States of America and by the citizens of the United States of America and all other persons subject to the jurisdiction thereof.
Page 537 - But when the terms of the stipulation import a contract — when either of the parties engages to perform a particular act — the treaty addresses itself to the political, not the judicial department ; and the legislature must execute the contract before it can become a rule for the Court.
Page 1136 - 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 720 - Any information so exchanged shall be treated as secret and shall not be disclosed to any persons other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or trade process.
Page 488 - The provisions of the present convention shall not be construed to restrict in any manner any exemption, deduction, credit, or other allowance accorded by the laws of one of the contracting states in the determination of the tax imposed by such state.
Page 640 - March 3, 1909 (two-thirds of the Senators present concurring therein), did advise and consent to the ratification of the said treaty...
Page 716 - State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions have accrued to one of the enterprises, but by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Page 11 - ... to encourage the development and use of cooperatives, credit unions, and savings and loan associations, to discourage monopolistic practices, to improve the technical efficiency of their industry, agriculture, and commerce, and to strengthen free labor unions; and...