Investment in Union of South Africa: Conditions and Outlook for United States Investors

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Page 18 - The par value of the currency of each member shall be expressed in terms of gold as a common denominator or in terms of the United States dollar of the weight and fineness in effect on July 1, 1944.
Page 142 - 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 143 - It is agreed that double taxation shall be avoided in the following manner: (a) The United States in determining the income taxes, including surtaxes, of its citizens, residents or corporations may, regardless of any other provision of this Convention, include in the basis upon which such taxes are imposed all items of income taxable under the revenue laws of the United States as if this convention had not come into effect.
Page 145 - ... and indefinitely after that period, but may be terminated by either of the contracting States at the end of the fiveyear period or at any time thereafter, provided that at least six months...
Page 143 - Rentals or royalties from property located in the United States or from any interest in such property, including rentals or royalties for the use of or for the privilege of using in the United States, patents, copyrights, secret processes and formulas, good will, trademarks, trade brands, franchises, and other like property; and (5) Gains, profits, and income from the sale of real property located in the United States.
Page 143 - Where an enterprise of one of the contracting 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...
Page 145 - With respect to the provisions of this Convention relating to exchange of information and mutual assistance in the collection of taxes, such authorities may, by common agreement, prescribe rules concerning matters of procedure, forms of application and replies thereto, conversion of currency, disposition of amounts collected, minimum amounts subject to collection and related matters.
Page 142 - person", "individual" and "corporation", shall have the same meanings, respectively, as they have under the revenue laws of the taxing State or the State furnishing the information, as the case may be; (b) the term "enterprise...
Page 143 - 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 143 - America, as though this Convention had not come into effect. The United States of America shall, however, deduct from the taxes thus computed the amount of Union income tax paid. This deduction shall be made in accordance with the benefits and limitations of Section 131 of the United States Internal Revenue Code as in effect on the day of the entry into force of this Convention. It is agreed that by virtue of the provisions of paragraph 2 of this Article the Union of South Africa satisfies the "...

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