Tax Treaties: Hearing Before the Committee on Foreign Relations, United States Senate, Ninety-seventh Congress, First Session, on Various Tax Treaties, (Ex. T, 96-2), (Ex. M, 96-2), (Ex. C, 94-2), (Ex. U 96-2), (Ex. H, 95-2), (Ex. O, 96-2), (Ex. Z, 96-2), (97-1), (Ex. E, 96-2), (97-10), (Ex. Y, 96-2), (Ex. C, 95-1), September 24, 1981
U.S. Government Printing Office, 1982 - 515 pages
What people are saying - Write a review
We haven't found any reviews in the usual places.
Other editions - View all
accordance activities addition agree agreement alienation allowed amount apply arise attributable Bangladesh basis benefits Business Profits Canada Canadian capital carried Chairman citizen Code Committee competent authorities concern CONGRESS connected considered contains contracting Convention corporation covered deduction deemed defined definition derived determining developing countries dividends double taxation effect enterprise example exceed excess exchange existing expenses extent Federal fixed base force foreign tax gains Government grant gross income tax individual industrial interest Internal Revenue Code investment issue Jamaica limitations Malta means negotiations operation paid paragraph payments percent performed period permanent establishment personal services Philippine present proposed treaty Protocol provides provisions of Article real property received referred regard resident respect royalties rules saving clause Senate similar situated specifically tax credit tax treaties taxable taxpayer term third tion Treasury U.S. Model U.S. tax United withholding
Page 213 - For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
Page 219 - The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as immovable property.
Page 243 - permanent establishment' shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise...
Page 472 - An alien actually present in the United States who is not a mere transient or sojourner is a resident of the United States for purposes of the income tax. Whether he is a transient is determined by his intentions with regard to the length and nature of his stay.
Page 179 - The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.
Page 218 - royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including...
Page 397 - interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures.
Page 267 - Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the firstmentioned...
Page 317 - State in which he has an habitual abode; c) if he has an habitual abode in both States or in neither of them...
Page 355 - immovable property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed...