Legislative History of United States Tax ConventionsU.S. Government Printing Office, 1962 - 4704 pages |
Contents
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Common terms and phrases
84th Congress aforesaid African convention agreement America apply article XIV Artikel avoidance of double capital CHAIRMAN Committee on Foreign Cong Congress contracting deemed derived from sources dividends double taxation effect enterprise entity estate tax evasion with respect Executive exempt from tax exempt from United fiscal evasion foreign countries Foreign Relations foreign tax credit Government income from sources income tax conventions income-tax India instruments of ratification interest Internal Revenue Code investment Japan Japanese June 13 ment Netherlands Antilles nonresident Norway paid Pakistan tax paragraph pending conventions percent permanent establishment present Convention prevention of fiscal profits reduced reservation resident or corporation respect to taxes royalties sess session signed at Washington South Africa Staat STAM staterna SURREY Sweden Swiss Switzerland tax imposed tax laws tax treaties tax-sparing taxable years beginning taxes on income taxpayer territory TIAS tion trade or business Treasury United Kingdom United States corporation United States tax vention Verdragsluitende Verenigde Staten Zealand
Popular passages
Page 1687 - 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 1716 - ... 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 1610 - Where an enterprise of one of the Contracting Parties is engaged in trade or business in the territory of the other Contracting Party 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...
Page 1784 - Mr. President, I ask unanimous consent that the order for the quorum call be rescinded. The PRESIDING OFFICER. Without objection, it is so ordered. Mr.
Page 2220 - Income exempt under treaty. Income of any kind, to the extent required by any treaty obligation of the United States; (8) Miscellaneous items.
Page 1787 - 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.
Page 1635 - taxation authorities" means, in the case of the United States, the Secretary of the Treasury or his delegate and, in the case of Israel, the Minister of Finance or his delegate. (2) In the application of the provisions of the present Convention...
Page 2734 - States tax. (3) The provisions of this Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by either of the Contracting Parties for purposes of profit.
Page 2386 - 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 shall be exchanged which would disclose any trade, business, industrial or professional secret or any trade process.
Page 1788 - ... behalf. An enterprise of one of the contracting States shall not be deemed to have a permanent establishment in the other...