Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1990 Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries. |
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Common terms and phrases
Administration annuities application August 11 Austria citizen commercial profits Commissioner of Internal competent authorities contracting Danish dends Department derived from sources divi dividends paid domestic corporation duplicate engaged in trade entity estate or trust excess tax withheld exempt from tax exempt from United Federal Acquisition Regulation fiduciary filed foreign corporation Form Greek corporation gross income income tax Internal Revenue Code Internal Revenue Service Ireland Irish tax items of income January letter of notification ment nent establishment nonresident alien individual notify the withholding Office owner Pakistan paragraph partnership paying corporation payment permanent establishment poration present Convention provisions of Article rate of tax real property reduced rate regulations resident of France resident of Switzerland respect royalties spect Sweden Swedish Swiss corporation tax at source tax was withheld taxable years beginning taxation taxpayer tion trade or business U.S. tax United States corporation United States tax vention withholding agent withholding of United
Popular passages
Page 92 - ... (B) from a foreign corporation unless less than 50 per centum of the gross income of such foreign corporation for the threeyear period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was derived from sources within the United States as determined under the provisions of this section...
Page 37 - ... by the United States of America and by the citizens of the United States of America and all other persons subject to the jurisdiction thereof.
Page 26 - Convention or for the prevention of fraud or the like in relation to the taxes which are the subject of the present Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or any trade process.
Page 160 - State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions have accrued to one of the enterprises, but by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Page 164 - Silver, the Commissioner, with the approval of the Secretary, shall prescribe and publish all needful rules and regulations for the enforcement of this title.
Page 26 - XI, at least six months prior notice of termination has been given, the termination to become effective on the first day of January following the expiration of the six-month period. Done...
Page 70 - Article 5: Permanent Establishment 1 . For the purposes of this Convention, the term 'permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
Page 130 - permanent establishment" when used with respect to an enterprise of one of the Contracting Parties means a branch, management, factory or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or has a stock of merchandise from which he regularly fills orders on its behalf.
Page 160 - Skattevaesenet) or his authorized representative. (2) In the application of the provisions of the present Convention by one of the contracting States any term not otherwise defined, shall, unless the context otherwise requires, have the meaning which such term has under its own tax laws.
Page 129 - Convention, unless the context otherwise requires: (a) The term "United States" means the United States of America, and when used in a geographical sense means the States, the Territories of Alaska and of Hawaii, and the District of Columbia.