Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and Index
Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries.
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15 percent accordance additional America amount annuities application Belgium bonds calendar carried citizen claim compensation Contracting Contracting Party controlled corporation coupon deemed derived from sources determination dividends domestic corporation duplicate effective engaged in trade enterprise entity exchange exempt from United Federal fiduciary filed foreign corporation Form Government gross income holding imposed income tax industrial interest Internal Revenue Code January laws letter of notification means ment Netherlands nonresident alien individual organized otherwise owner paid paragraph partnership paying payment pensions percent period permanent establishment person personal services poration prescribed present Convention profits provisions provisions of Article pursuant real property received reduced rate referred regulations relating release rentals resident respect royalties securities situated statement taxable taxation taxpayer term territory therein thereof tion tracting trade or business United Kingdom United States tax unless vention withholding agent withholding of United
Page 387 - 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 323 - Convention or for the prevention of fraud or for the administration of statutory provisions against legal avoidance 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 persons other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information as aforesaid shall be exchanged which would disclose any trade, business,...
Page 131 - 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. An enterprise of one of the Contracting Parties shall not be deemed to have a permanent...
Page 387 - States is engaged in trade or business in the territory of the other contracting State through a permanent establishment situated therein, there shall be attributed to such permanent establishment the industrial or commercial profits 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 and dealing at arm's length with the enterprise of which it is a permanent establishment...
Page 407 - I National Park Service, Department of the Interior II Forest Service, Department of Agriculture . III Corps of Engineers, Department of the Army IV American Battle Monuments Commission V Smithsonian Institution Title 37 — Patents, Trade-Marks, and Copyrights I Patent Office, Department of Commerce II Copyright Office, Library of Congress Title 38 — Pensions, Bonuses, and Veterans' Relief I Veterans Administration Title 39 — Postal Service I Post Office Department Title 40— [Reserved!
Page 89 - permanent establishment", when used with respect to an enterprise of one of the Contracting States, means a branch, 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 behalf of such enterprise. An enterprise of one of the Contracting States...
Page 252 - ... or which may hereafter be granted to, such officers. (2) The provisions of the present 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.
Page 134 - annuity" means a stated sum payable periodically at stated times, during life or during a specified or ascertainable period of time, under an obligation to make the payments in return for adequate and full consideration in money or money's worth.
Page 240 - SEC. 7805. Rules and regulations — (a) Authorization. Except where such authority is expressly given by this title to any person other than an officer or employee of the Treasury Department, the Secretary or his delegate shall prescribe all needful rules and regulations for the enforcement of this title including all rules and regulations as may be necessary by reason of any alteration of law in relation to internal revenue.
Page 367 - An enterprise of one of the contracting States is not subject to taxation by the other contracting State in respect of its industrial and commercial profits except in respect of such profits allocable in accordance with the Articles of this Convention to its permanent establishment in the latter State.