Legislative History of United States Tax ConventionsU.S. Government Printing Office, 1962 - 4704 pages |
Contents
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Common terms and phrases
85th Congress amended apply approved Australia avoidance of double Belgian Belgium British Canadian CARROLL CHAIRMAN collection Committee on Foreign Cong Congress convention and protocol decedent dividends Doctor ADAMS domiciled double taxation effect enterprise entity estate tax Etats contractants Etats-Unis exchange Executive existing convention Finland fiscal evasion foreign country Foreign Relations foreign tax France French GARNER Government income tax income-tax convention instruments of ratification interest Internal Revenue Code KING licensor ment negotiated nonresident alien Norway October 28 Pakistan paragraph pending convention percent permanent establishment present Convention prevention of fiscal principle profits provisions question real property reciprocal exemption rentals resident or corporation respect to taxes royalties Ruanda-Urundi Secretary Senator GEORGE Senator SMITH sess session signed at Washington South Africa STAM supplementary convention supplementary protocol tax conventions tax imposed tax treaties taxable taxes on income taxpayer territories tion United Kingdom United States tax vention
Popular passages
Page 529 - It would not be contended that it extends so far as to authorize what the Constitution forbids, or a change in the character of the government or in that of one of the States, or a cession of any portion of the territory of the latter, without its consent.
Page 390 - Mr. President, I ask unanimous consent that the order for the quorum call be rescinded. The PRESIDING OFFICER. Without objection, it is so ordered.
Page 527 - If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, penalty, additional amount, or addition to such tax, together with any costs that may accrue in addition thereto) shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.
Page 417 - ... not engaged in trade or business within the United States and not having an office or place of business therein, from sources within the United States as interest (except interest on deposits with persons carrying on the banking business), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income...
Page 100 - Chairman, if you have any questions I will be glad to try to answer them, or Mr.
Page 539 - Our constitution declares a treaty to be the law of the land. It is, consequently, to be regarded in courts of justice as equivalent to an act of the legislature, whenever it operates of itself without the aid of any legislative provision. But when the terms of the stipulation import a contract, when either of the parties engages to perform a particular act, the treaty addresses itself to the political, not the judicial department; and the legislature must execute the contract before it can become...
Page 643 - And whereas, the Senate of the United States by their resolution of March 3, 1909 (two-thirds of the Senators present concurring therein), did advise and consent to the ratification of the said treaty...
Page 719 - 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 208 - ... if it were an independent enterprise engaged in the same or similar activities under the same or similar conditions...
Page 783 - ... basis upon which such taxes are imposed all items of income taxable under the revenue laws of the United States of America as though this Convention had not come into effect.