The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1971 The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Common terms and phrases
15 percent annuities application Article VI Article VII Article XI Belgian Congo Belgium calendar citizen commercial profits Commissioner of Internal competent authorities Contracting Party coupon bond interest deemed dends derived from sources dividends paid domestic corporation engaged in trade entity estate or trust excess tax withheld exempt from United Federal fiduciary filed Finland Finnish foreign corporation Form gross income income tax Internal Revenue Code Internal Revenue Service items of income January letter of notification means ment nent establishment Netherlands nonresident alien individual Norway notify the withholding owner Pakistan paragraph partnership payment permanent establishment personal services poration present Convention provisions of Article rate of tax rate of United real property reduced rate resident or corporation spect Switzerland tax at source tax imposed tax was withheld taxable years beginning taxpayer territory tion trade or business U.S. tax United States corporation United States dollars United States tax vention withholding agent withholding of United
Popular passages
Page 107 - permanent establishment" when used with respect to an enterprise of one of the Contracting Parties means a branch, management, factory or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or has a stock of merchandise from which he regularly fills orders on its behalf. An enterprise of one of the Contracting Parties...
Page 323 - Convention or for the prevention of fraud or for the administration of statutory provisions against legal avoidance in relation to the taxes which are the subject of the present Convention. 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 as aforesaid shall be exchanged which would disclose any trade, business,...
Page 215 - SEC. 7805. Rules and regulations — (a) Authorization. Except where such authority is expressly given by this title to any person other than an officer or employee of the Treasury Department, the Secretary or his delegate shall prescribe all needful rules and regulations for the enforcement of this title, including all rules and regulations as may be necessary by reason of any alteration of law in relation to internal revenue.
Page 201 - 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 31 - permanent establishment," when used with respect to an enterprise of one of the Contracting States, means a branch, factory, mine, oil well, plantation, workshop, warehouse, installation, or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or has control over a stock of merchandise from which he regularly fills orders on behalf of such enterprise. An enterprise...
Page 109 - life annuity" means a stated sum payable periodically at stated times, during life or during a specified or ascertainable period of time, under an obligation to make the payments in consideration of money paid.
Page 201 - States is engaged in trade or business in the territory of the other contracting State through a permanent establishment situated therein, there shall be attributed to such permanent establishment the industrial or commercial profits which it might be expected to derive if it were an independent enterprise engaged in the same or similar activities under the same or similar conditions and dealing at arm's length with the enterprise of which it is a permanent establishment...
Page 203 - States in the determination of the tax imposed by such State. (3) Should any difficulty or doubt arise as to the interpretation or application of the present Convention, or its relationship to Conventions between one of the contracting States and any other State, the competent authorities of the contracting States may settle the question by mutual agreement.
Page 367 - An enterprise of one of the contracting States is not subject to taxation by the other contracting State in respect of its Industrial and commercial profits except in respect of such profits allocable in accordance with the Articles of this Convention to its permanent establishment in the latter State.
Page 107 - ARTICLE II (1) In the present Convention, unless the context otherwise requires: (a) The term "United States" means the United States of America, and when used in a geographical sense means the States, the Territories of Alaska and of Hawaii, and the District of Columbia. (b) The term "United Kingdom" means Great Britain and Northern Ireland, excluding the Channel Islands and the Isle of Man.