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 433by United States. Internal Revenue Service - 1979Full view - About this book
| 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... | |
| 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... | |
| 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... | |
| 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... | |
| 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... | |
| 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... | |
| 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... | |
| 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... | |
| 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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