Code of Federal Regulations: 1949-1984U.S. General Services Administration, National Archives and Records Service, Office of the Federal Register, 1970 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
15 percent annuities application Article VI Article VII Article XI Belgian Congo Belgium calendar citizen commercial profits Commissioner of Internal competent authorities Contracting Party deemed dends derived from sources dividends paid domestic corporation engaged in trade entity estate or trust excess tax withheld exempt from United Federal fiduciary filed Finland Finnish foreign corporation Form gross income income tax Internal Revenue Code Internal Revenue Service items of income January letter of notification means ment nent establishment Netherlands nonresident alien individual Norway notify the withholding owner Pakistan paragraph partnership payment permanent establishment personal services poration present Convention provisions of Article rate of tax rate of United real property reduced rate regulations resident or corporation spect Switzerland tax at source tax imposed tax was withheld taxable years beginning taxpayer territory tion trade or business U.S. tax United States corporation United States dollars United States tax vention withholding agent withholding of United
Popular passages
Page 371 - 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 307 - 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 115 - 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 371 - 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 391 - 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 73 - 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 236 - ... 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 118 - 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 224 - 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 351 - 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.