Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and the Russian Federation: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 27, 1993U.S. Government Printing Office, 1993 - 60 pages |
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Common terms and phrases
activities alternative minimum tax amount attributable branch profits tax competent authority coun country of residence dends derived dividends dividends paid double taxation effectively connected entity erally establishment or fixed fixed base foreign corporation foreign person foreign source income foreign tax credit gains income tax treaties independent personal services interest paid internal law international traffic investment investor ment nonresident alien OECD model treaties passive income payments percent permanent establishment portfolio posed treaty proposed protocol proposed treaty contains proposed treaty provides purposes recent U.S. REMIC resi restriction royalties rules Russian Federation Russian resident Russian tax saving clause second country similar source country taxation taxable taxes imposed taxing jurisdiction taxpayers third country tion trade or business trea treaty benefits U.S. and OECD U.S. citizens U.S. corporation U.S. income tax U.S. law U.S. model treaty U.S. person U.S. resident U.S. source income U.S. tax treaties U.S. trade United USSR treaty withholding tax
Popular passages
Page 14 - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 37 - dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation...
Page 57 - Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more...
Page 58 - State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
Page 35 - ... income that is treated as effectively connected with the conduct of a US trade or business. The...
Page 59 - State; c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
Page 15 - Hearings Before the Subcommittee on Oversight of the House Committee on Ways and Means, 101st Cong., 2d Sess.
Page 42 - royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including...
Page 25 - But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.
Page 26 - State in which he has his centre of vital interests cannot be determined, or if he...