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According activities addition agree agreement allow amount apply arise Article attributable banks basis benefits business profits capital charitable citizens Code Committee competent authority conduct contributions coun covered deductions derived determined dividends double taxation earned effectively connected enterprise entity example exchange excise tax exemption expenses extent fixed base foreign corporation foreign tax credit gain granted gross imposed income tax treaties independent individual interest Internal Revenue Code investment limitation means Mexican Mexico operation organization paid paragraph payments percent performed period permanent establishment permit person personal services posed present proposed protocol proposed treaty proposed treaty provides provision received reduced requested resident respect royalties rules ships similar situated source income specifies taxable taxation term tion trade or business treaty country U.S. income tax U.S. model treaty U.S. person U.S. source U.S. tax United withholding tax
30. lappuse - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
18. lappuse - The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention.
101. lappuse - State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
55. lappuse - 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.
45. lappuse - corporation" includes associations, joint-stock companies, and insurance companies. (4) Domestic. The term "domestic" when applied to a corporation or partnership means created or organized in the United States or under the law of the United States or of any State or Territory. (5) Foreign. The term "foreign" when applied to a corporation or partnership means a corporation or partnership which is not domestic.
57. lappuse - 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.
28. lappuse - ... income that is treated as effectively connected with the conduct of a US trade or business, a portion of such dividend will be considered US source income.
5. lappuse - However, no such deduction shall be allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the...