Tax Conventions with the Philippines and France: Hearing ... 90-2, on Tax Convention with the Philippines (Executive D, 89th Congress, 1st Session), Tax Convention with France (Executive N, 90th Congress, 1st Session), April 30, 19681968 - 72 pages |
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Common terms and phrases
15 percent activities agreement ALBERT GORE American corporation apply article provides branch profits tax Brazilian CARROLL CHAIRMAN charitable commercial profits Committee competent authorities convention with France corporate tax dividend tax dividends distributed dividends paid double taxation effectively connected establishment clause exempt from tax extraterritorial foreign corporations foreign tax credit French company French corporation French subsidiary French tax French treaty Government Hearne included income from personal income tax convention income tax treaty independent agent industrial or commercial interest Internal Revenue Code investment tax nonresident OECD draft OECD model convention payments permanent establishment personal service income Philippine treaty proposed convention purpose rate of tax ratification real property resident or corporation respect royalties Senator PELL Senator SPARKMAN shareholders ship or aircraft subject to tax SURREY tax credit tax law tax on dividends taxable Thailand treaty tion Treasury treaty with Brazil treaty with France treaty with Thailand U.S. corporation withholding tax
Popular passages
Page 24 - permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term 'permanent establishment...
Page 26 - States derives from the operation in international traffic of ships or aircraft registered in the United States shall be exempt from tax by Trinidad and Tobago.
Page 43 - State, or (ii) securing training required to qualify him to practice a profession or professional specialty, or (iii) studying or doing research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization, shall be exempt from tax by that other Contracting State with respect to amounts described in subparagraph (b).
Page 33 - Convention shall not be construed to restrict in any manner any exemption, deduction, credit or other allowance now or hereafter accorded, by the laws of one of the contracting States in the determination of the tax imposed by such State, or by any other agreement between the contracting States.
Page 71 - The committee, therefore, recommends that the Senate give its advice and consent to the ratification of the pending...
Page 44 - Article be construed so as to impose upon either of the contracting States the obligation to carry out administrative measures at variance with the regulations and practice of either contracting State or which would be contrary to its sovereignty, security or public policy or to supply particulars which are not procurable under its own legislation or that of the State making application.
Page 37 - The Convention shall also apply to any identical or substantially similar taxes which are subsequently imposed in addition to, or in place of, the existing taxes. At the end of each year, the competent authorities of the Contracting States shall notify to each other any changes which have been made in their respective taxation laws.
Page 35 - Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the State of which he is a resident...
Page 30 - If, in the case of a taxable year beginning in 1954 and ending in 1955, a taxpayer is not engaged in trade or business in the United States through a permanent establishment at any time during that part of the taxable year which follows December 31.
Page 43 - The benefits under this paragraph shall only extend for such period of time as may be reasonably or customarily required to effectuate the purpose of the visit, but in no event shall any individual have the benefits of this Article and Article 17 for more than a total of five taxable years.