Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1999 Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries. |
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Common terms and phrases
annuities application August 11 calendar citizen commercial profits Commissioner of Internal competent authorities contracting dends dent derived from sources dividends paid domestic corporation engaged in trade entity estate or trust excess tax withheld exempt from taxation exempt from United Federal Acquisition Regulation fiduciary filed foreign corporation Form French corporation gross income holding agent Internal Revenue Code Internal Revenue Service Ireland Irish tax items of income January letter of notification ment nent establishment nonresident alien individual notify the withholding owner Pakistan paragraph partnership payment permanent establishment personal services poration present Convention provisions of Article rate of tax real property reduced rate regulations resi resident alien resident of France resident or corporation respect royalties spect Sweden Swedish Swiss corporation tax at source tax was withheld taxable years beginning taxpayer tion tracting trade or business U.S. tax United States corporation United States tax vention vidual withholding agent withholding of United
Popular passages
Page 60 - Convention by a Contracting State, any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of the Convention. Article 4 FISCAL DOMICILE 1. For the purposes of this Convention, the term "resident of a Contracting State...
Page 104 - 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 return for adequate and full consideration in money or money's worth. Article...
Page 30 - ... by the United States of America and by the citizens of the United States of America and all other persons subject to the jurisdiction thereof.
Page 18 - Convention or for the prevention of fraud or the like 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 person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or any trade process.
Page 127 - 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 129 - Silver, the Commissioner, with the approval of the Secretary, shall prescribe and publish all needful rules and regulations for the enforcement of this title.
Page 129 - June 6, 1932, the compensation received as such shall be included in gross income. (b) Exclusions from gross income. The following items shall not be included in gross income and shall be exempt from taxation under this chapter: (1) Life insurance.
Page 127 - Income which an enterprise of one of the contracting States derives from the operation of ships or aircraft registered in that State shall be exempt from taxation in the other contracting State.
Page 90 - The provisions of this Convention shall not be construed to deny or affect in any manner the right of diplomatic and consular officers to other or additional exemptions now enjoyed or which may hereafter be granted to such officers.
Page 98 - 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.