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accordance Administration America amount annuities application bond calendar carried citizen claim Commissioner of Internal compensation contracting corporation coupon Danish deemed Denmark dent Department derived derived from sources determination dividends domestic corporation duplicate enterprise entity exchange exempt from United Federal filed Form France French Greek corporation gross income holding imposed income tax industrial interest Internal Revenue Code Ireland items of income January laws letter letter of notification means ment nonresident alien individual Office otherwise owner paid Pakistan paragraph partnership paying payment pensions percent period permanent establishment person poration prescribed present Convention profits provisions of Article real property received reduced rate regulations relating release rentals resi resident respect royalties securities sources Sweden Swiss Switzerland taxable taxation taxpayer term therein tion tracting trade or business United States tax unless vention withholding agent withholding of United
Page 54 - 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 96 - 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 24 - ... 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 12 - 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 120 - 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 123 - 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 123 - 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 120 - 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 82 - 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 91 - 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.