| United States. Congress. Senate. Committee on Finance - 1946 - 910 pages
...Contracting Parties is engaged in trade or business in the territory of the other Contracting Party through a permanent establishment situated therein, there...shall, subject to the law of such other Contracting Party, be deemed to be income from sources within the territory of such other Contracting Party. (4)... | |
| United States. Congress. Senate. Committee on Foreign Relations - 1945 - 138 pages
...establishment in New York, under paragraph (3) of article III there shall be attributed to the New York branch the industrial or commercial profits which it might...profits so attributed shall, subject to the law of the country in question, be deemed to be income from sources within its territory. However, in accordance... | |
| United States. Congress. Senate. Foreign Relations - 1945 - 94 pages
...establishment in New York, under paragraph (3) of article III there shall be attributed to the New York branch the industrial or commercial profits which it might...profits so attributed shall, subject to the law of the country in question, be deemed to be income from sources within its territory. However, in accordance... | |
| United States. Congress. Joint Committee on Internal Revenue Taxation - 1946 - 428 pages
...Contracting Parties is engaged in trade or business in the territory of the other Contracting Party through a permanent establishment situated therein, there...shall, subject to the law of such other Contracting Party, be deemed to be income from .sources within the territory of such other Contracting Party. (4)... | |
| 1990 - 214 pages
...contracting States of the mere purchase of merchandise therein by an enterprise of the other State. (3) Where an enterprise of one of the contracting...at arm's length with the enterprise of which it is a permanent establishment. 26 CFR Ch. I (4-1-90 Edition) (4) In the determination of the industrial... | |
| 1980 - 476 pages
...Contracting Parties Is engaged In trade or business in the territory of the other Contracting Party through a permanent establishment situated therein, there...dealing at arm's length with the enterprise of which It U a permanent establishment, and the profits so atTitle 26 — Internal Revenue trlbuted shall, subject... | |
| 1968 - 416 pages
...therein, there shall be attributed to such permanent establishment the industrial or commercial profite which it might be expected to derive if it were an...which it is a permanent establishment and the profits eo attributed shall, subject to the law of such other contracting State, be deemed to be Income from... | |
| 1974 - 436 pages
...were an independent enterprise engaged In the same or similar activities under the same or sunliar conditions and dealing at arm's length with the enterprise...shall, subject to the law of such other Contracting Party, be deemed to be Income from sources within the territory of auch other Contracting Party. (4)... | |
| 1954 - 1486 pages
...similar activities under the same or similar conditions and dealing at arm's length aith the enterprise of which It is a permanent establishment, and the...State, be deemed to be Income from sources within such other Confracting State. (3) In determining the Industrial or commercial profits from sources... | |
| United States - 1954 - 830 pages
...contracting States of the mere purchase of merchandise therein by an enterprise of the other State. (3) Where an enterprise of one of the contracting...at arm's length with the enterprise of which it is a permanent establishment. (4) In the determination of the industrial or commercial profits of the... | |
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