 | United States. Internal Revenue Service - 1976 - 624 pages
...that the income derived by such person is subject to United States tax as the income of a resident. (2) Where by reason of the provisions of paragraph (1) an individual is a resident of both Contracting States: (a) He shall be deemed to be a resident of that Contracting State in which he maintains... | |
 | United States. Internal Revenue Service - 1979 - 644 pages
...partnership shall be considered a resident of the State under the laws of which it was created or organized. (2) Where by reason of the provisions of paragraph (1) an individual is a resident of both Contracting States: (a) He shall be deemed to be a resident of that Contracting State in which he maintains... | |
 | Pompiliu Verzariu, Jay A. Burgess - 1977 - 110 pages
...or trust only to the extent that the income derived by such person is subject to United States tax. (2) Where by reason of the provisions of paragraph (1) an individual is a resident of both Contracting States: (a) He shall be deemed to be a resident of that Contracting State in which he maintains... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 pages
...with individuals. A "dual resident" individual is initially deemed to be a resident of the Contracting State in which he has a permanent home available to him. If the individual has a permanent home available to him in both States or in neither, he is deemed to... | |
 | P. Drillien, Euye - 1984 - 892 pages
...whose estate or whose gift is liable to tax in that State only in respect of property situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is domiciled in both Contracting States, then his status shall be determined as follows: (a) he shall... | |
 | 1992 - 858 pages
...of a resident, either in its hands or in the hands of its partners or beneficiaries. 2. '..'here by reason of the provisions of paragraph 1 an individual...both Contracting States, then his status shall be deterninpd as follows: a) he shall be deened to be a resident of the State in which no has a pernanent... | |
 | Ssociation Espanola De Profesores De Der - 1996 - 506 pages
...residence, headquarters, or central office, or any other criteria of a similar nature. 2. When by virtue of the provisions of paragraph 1 an individual is a resident of both contracting States, his situation will be determined in accordance with the following rules: a) This... | |
 | Pasquale Pistone - 2002 - 424 pages
...tax in that State in respect only of income from sources in that State or capital situated therein. 2. Where by reason of the provisions of paragraph...determined as follows: a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him: if he has a permanent... | |
 | United Nations Staff - 2002 - 564 pages
...reason of his domicile, residence, place of management or any other criterion of a similar nature. 2. Where by reason of the provisions of paragraph...Contracting States, then his status shall be determined in accordance with the following rules: (a) He shall be deemed to be a resident of the State in which... | |
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State or capital situated therein. 2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States... 
