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" 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... "
Internal Revenue Cumulative Bulletin - Page 433
by United States. Internal Revenue Service - 1979
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Internal Revenue Bulletin: Cumulative bulletin

United States. Internal Revenue Service - 1968 - 1034 pages
...maintained by a resident of France in the United States. <3) A corporation of a Contracting State, the capital of which is wholly or partly owned or...not be subjected in the first-mentioned Contracting Htate to any taxation or any requirement connected therewith which is other or more burdensome than...
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Model tax conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 724 pages
...family responsibilities which it grants to its own residents. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or...first-mentioned Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1971 - 816 pages
...family responsibilities which it grants to its own residents. 3. A corporation of a Contracting State, the capital of which is wholly or partly owned or...and connected requirements to which a corporation of that first-mentioned Contracting State carrying on the same activities, the capital of which is wholly...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1977
...benefits granted by special agreements to permanent establishments of a third State. (3) A company he property, or (2) the right, either alone or in conjunction with any person, requirement connected with taxation which is other or more burdensome than the taxation and requirements...
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Internal Revenue Cumulative Bulletin, Issue 2

United States. Internal Revenue Service - 1972 - 624 pages
...Contracting States, the capital of which is wholly or partly owned by one or more nationals or corporations of the other Contracting State, shall not be subjected in the first-mentioned Contracting State to more burdensone taxes than is a corporation of that Contracting State. ARTICLE 7 * TAX DEFERRAL FOR...
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Joint Venture Agreements in Romania: Background for Implementation, Volume 57

Pompiliu Verzariu, Jay A. Burgess - 1977 - 110 pages
...tax benefits granted by special agreements to citizens or permanent establishments of a third State. (3) A corporation of one of the Contracting States,...first-mentioned Contracting State to any taxation or any requirement connected with taxation which is other or more burdensome than the taxation and requirements...
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United States Congressional Serial Set

1987 - 948 pages
...been contracted to a resident of the first-mentioned State. 4. Enterprises of a Contracting State, the capital of which is wholly or partly owned or...State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than...
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Congressional Serial Set

1992 - 858 pages
...they had been paid to a resident of the first-mentioned State. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or...State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than...
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Multilateral Tax Treaties

Helmut Loukota, Albert J. Rädler, Josef Schuch, Franz Wassermeyer, Gerald Toifl, Christoph Urtz - 1998 - 266 pages
...been contracted to a resident of the first-mentioned State. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or...State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than...
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Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries

Daniel Sandler - 1998 - 326 pages
...of the treaty with Brazil provides: Non-distributed profits of a corporation of a Contracting State, the capital of which is wholly or partly owned or...residents of the other Contracting State, shall not be taxable in the last-mentioned State. This provision appears to be directly in conflict with Denmark's...
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