Tax Conventions with Belgium, Finland, Trinidad and Tobago, and the Netherlands: Hearings, Ninety-first Congress, Second Session ... October 6, and November 19, 1970U.S. Government Printing Office, 1971 - 177 pages |
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Common terms and phrases
allow a credit amount apply Article provides Belgian corporation Belgian law Belgium business profits capital gains CHAIRMAN COHEN commercial profits competent authorities CONGRESS THE LIBRARY continental shelf death taxes decedent decedent's deduction definition dividends dividends paid domicile domiciliary double taxation Dutch effectively connected estate tax treaties exchange exempt from tax Finland Finnish tax foreign tax credit income tax convention income tax treaties individual industrial or commercial interest Internal Revenue Code investment LIBRARY OF CONGRESS limited Netherlands nonresident alien OECD Model Convention payments permanent establishment proposed convention contains proposed convention provides purposes real property recent U.S. recipient reduced rate respect royalties section 351 Senator CHURCH ships or aircraft similar source country source rule subject to tax tax imposed tax laws taxable temporarily present term tion Tobago corporation transfer Trinidad and Tobago U.S. citizen U.S. corporation U.S. income tax United States corporation United States tax vention withholding tax WOODWORTH worldwide estate
Popular passages
Page 94 - States as determined under the provisions of this part; but only in an amount which bears the same ratio to such dividends as the gross income of the corporation for such period derived from sources within the United States bears to its gross income from all sources...
Page 81 - 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 146 - State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, and b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
Page 64 - Paragraph 1 of this Article shall not apply if the recipient of the interest, being a resident of one of the Contracting States, has a permanent establishment in the other Contracting State and the indebtedness giving rise to the interest is effectively connected with such permanent establishment.
Page 151 - ... personal services) with respect to mines, oil and gas wells and other natural deposits, the term "United States...
Page 92 - 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 76 - Convention by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State concerning the taxes to which the Convention applies. Article 4. RESIDENT 1 . For the purposes of this Convention, the term "resident of a Contracting State...
Page 59 - ... d) The maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or for collecting information, for the...
Page 142 - State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.
Page 66 - ... of, or of other Individuals exercising similar functions in corporations created or organized In Belgium; (b) He is temporarily present within Belgium for a period or periods not exceeding a total of one hundred eighty-three days during the calendar year and his compensation is received for labor or personal services performed as a worker or employee of, or under contract with, a resident of, or a corporation...