Tax Treaties with the United Kingdom, the Republic of Korea, and the Republic of the Philippines: Hearings Before the Committee on Foreign Relations, United States Senate, Ninety-fifth Congress, First Session ... July 19 and 20, 1977U.S. Government Printing Office, 1977 - 496 pages |
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actor advance corporation tax affiliates airlines allocation American amount apply arm's length Article 9 Article 9(4 article XI ASARCO Bank benefits British business profits Chairman citizen combined reporting Committee companies Contracting corporate tax determining dividends double taxation earnings effect enterprise Federal foreign corporations Foreign Relations foreign source income foreign tax credit Franchise Tax Board Government income tax treaty interest Internal Revenue Code Internal Revenue Service investment JOHN SPARKMAN legislation limited ment multinational corporations negotiations operations paragraph parent payments percent permanent establishment personal services Philippine proposed treaty ratification refund resident respect royalties rules Section 482 Senator CHURCH Senator JAVITS Senator Lucas subsidiary tax authorities tax liability tax system taxable taxpayer tion U.K. corporation U.K. treaty U.S. Senate U.S. shareholders U.S. tax unitary apportionment unitary business unitary concept unitary formula unitary method unitary system unitary tax United Kingdom United States tax withholding tax WOODWORTH worldwide
Popular passages
Page 349 - ... in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
Page 220 - ... (a) separate accounting; (b) the exclusion of any one or more of the factors; (c) the inclusion of one or more additional factors which will fairly represent the taxpayer's business activity in this State; or (d) the employment of any other method to effectuate an equitable allocation and apportionment of the taxpayer's income.
Page 328 - For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
Page 466 - A person acting in a Contracting State on behalf of an enterprise of the other Contracting State — other than an agent of an independent status to whom paragraph 5 applies — shall be deemed to be a permanent establishment...
Page 359 - 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 203 - It is quite apparent that if, in the maintenance of our international relations, embarrassment — perhaps serious embarrassment — is to be avoided and success for our aims achieved, congressional legislation which is to be made effective through negotiation and inquiry within the international field must often accord to the President a degree of discretion and freedom from statutory restriction which would not be admissible were domestic affairs alone involved.
Page 155 - Business income" means income arising from transactions and activity in the regular course of the taxpayer's trade or business and includes income from tangible and intangible property if the acquisition, management, and disposition of the property constitute integral parts of the taxpayer's regular trade or business operations. (b) "Commercial domicile" means the principal place from which the trade or business of the taxpayer is directed or managed.
Page 371 - In accordance with the provisions and subject to the limitations of the law of the United States (as it may be amended from time to time without changing the general principle hereof...
Page 351 - Article be construed so as to impose upon either of the contracting States the obligation to carry out administrative measures at variance with the regulations and practice of either contracting State or which would be contrary to its sovereignty, security or public policy or to supply particulars which are not procurable under its own legislation or that of the State making application.
Page 203 - The nature of foreign negotiations requires caution ; and their success must often depend on secrecy ; and, even when brought to a conclusion, a full disclosure of all the measures, demands, or eventual concessions which may have been proposed or contemplated would be extremely impolitic ; for this might have a pernicious influence on future negotiations, or produce immediate inconveniences, perhaps danger and mischief, in relation to other powers.