Tax Convention with Thailand: Hearings, Eighty-ninth Congress, First Session. August 11, 13, 18, 25, 1965U.S. Government Printing Office, 1965 - 181 pages |
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25 percent 7-percent credit abroad Albert Gore American amount articles 13 assets baht benefits capital Chairman committee CONGRESS THE LIBRARY considered Contracting convention with Thailand deduction depreciation reserve dividends domestic investment double taxation earnings effect eligible corporation encourage enterprise exchange exempt from tax export foreign country foreign investment credit foreign tax credit Government Honduras income from personal income tax conventions interest Internal Revenue Code investment in Thailand investors less developed countries LIBRARY OF CONGRESS limited ment negotiations operation Pakistan paragraph pending treaty permanent establishment private investment profits provision purpose question ratification resident or corporation respect royalties Senator GORE Senator PELL Senator SYMINGTON SOLOMON subcommittee subsidiary SURREY tax laws tax rates tax sparing tax treaties taxable Thai tax Thailand treaty tion trade or business treaty with Thailand U.S. corporation U.S. income tax U.S. investment U.S. residents U.S. tax United WOODWORTH
Popular passages
Page 153 - To the Senate of the United States : With a view to receiving the advice and consent of the Senate to ratification...
Page 175 - Convention. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at...
Page 160 - ... conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, Have...
Page 175 - shall be entitled to lodge a claim with the State of which he Is a citizen or resident or, if the taxpayer is a corporation or other entity, with the State In which It was created or organized. If the claim should be deemed worthy of consideration, the competent authority of such State may consult with the competent authority of the other State to determine whether the double taxation in question may be avoided...
Page 161 - In the application of the provisions of the present convention by one of the contracting parties any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that contracting party relating to the taxes which are the subject of the present convention.
Page 163 - If an enterprise of one of the contracting States has a permanent establishment in the other State, there shall be attributed to such permanent establishment the net industrial and commercial profit 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 161 - 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 167 - ... in the management, control or capital of the other or if the same persons participate directly or indirectly in the management, control or capital of both enterprises.
Page 174 - Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons...
Page 171 - United States. — The following items of gross income shall be treated as income from sources without the United States...