The Code of Federal Regulations of the United States of AmericaU.S. Government Printing Office, 1990 The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. |
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Common terms and phrases
Administration annuities application August 11 Austria citizen commercial profits Commissioner of Internal competent authorities contracting 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 Federal Register 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 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 tracting trade or business U.S. tax United States corporation United States tax vention withholding agent withholding of United
Popular passages
Page 84 - interest" as used in this Article means income from Government securities, bonds or debentures, whether or not secured by mortgage and whether or not carrying a right to participate in profits, and debt-claims of every kind as well as all other income assimilated to income from money lent by the taxation law of the State in which the income arises.
Page 96 - June 6, 1932, the compensation received as such shall be included in gross income. (b) Exclusions from gross income. The following items shall not be included in gross income and shall be exempt from taxation under this chapter: (1) Life insurance.
Page 28 - 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 17 - pensions", as used in this Article, means periodic payments made In consideration for services rendered or by way of compensation for Injuries received. (4) The tern "life annuities" as used in this Article, means a stated sum payable periodically at stated times during life, or during a specified number of years, under an obligation to make the payments in return for adequate and full consideration in money or money's worth.
Page 27 - Industrial or commercial profits In accordance with the laws of the contracting States. (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 auch term bas under its own taz laws.
Page 138 - ARTICLE! (1) The taxes referred to in this Convention are: (a) In the case of the United States of America: The Federal income tax, including surtaxes.
Page 54 - January 1, 1951, referred to in this subpart as the convention, provides in part as follows: ARTICLE I (1) The taxes which are the subject of the present Convention are: (a) In the United States of America: The Federal income taxes, including surtaxes (hereinafter referred to as United States tax).
Page 116 - 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 115 - 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.
Page 79 - ... (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...