Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between the United States and Mexico: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 27, 1993U.S. Government Printing Office, 1993 - 104 lappuses |
No grāmatas satura
1.–5. rezultāts no 27.
4. lappuse
... competent author- ity determination ( on the basis of mutual agreement ) on the mode of application of the treaty to ... authority to conclude contracts in the name of the enterprise , unless the activities of the agent are limited to ...
... competent author- ity determination ( on the basis of mutual agreement ) on the mode of application of the treaty to ... authority to conclude contracts in the name of the enterprise , unless the activities of the agent are limited to ...
7. lappuse
... competent authority of that country is inadequate to determine the profits to be attributed to a permanent establishment or in the cases covered by Article 23 of the Income Tax Law of Mexico , provided that , on the basis of the ...
... competent authority of that country is inadequate to determine the profits to be attributed to a permanent establishment or in the cases covered by Article 23 of the Income Tax Law of Mexico , provided that , on the basis of the ...
8. lappuse
... competent authorities of the two coun- tries would be required to consult with each other to determine whether the ... authority by the Mexican competent au- thority that Mexico has authorized the marketing of securitized mortgages in a ...
... competent authorities of the two coun- tries would be required to consult with each other to determine whether the ... authority by the Mexican competent au- thority that Mexico has authorized the marketing of securitized mortgages in a ...
13. lappuse
... competent authority review in sufficient time so that the competent authority of the other country is notified within four and a half years from the due date or the date of filing of the return at issue in that country , whichever is ...
... competent authority review in sufficient time so that the competent authority of the other country is notified within four and a half years from the due date or the date of filing of the return at issue in that country , whichever is ...
16. lappuse
... competent authority of the country in which the income arises the ability to override this standard . The proposed treaty provides that in making such a determination , one factor the competent authority should take into account is ...
... competent authority of the country in which the income arises the ability to override this standard . The proposed treaty provides that in making such a determination , one factor the competent authority should take into account is ...
Citi izdevumi - Skatīt visu
Bieži izmantoti vārdi un frāzes
alimony amount apply assets tax attributable branch profits tax business profits charitable organization competent authority coun country of residence deductions dividends paid double taxation earned effectively connected enterprise entity establishment or fixed excise tax exemption fixed base foreign corporation foreign source income foreign tax credit immovable property income tax treaties interest paid limitation Mexican law Mexican resident NAFTA nonresident alien OECD model treaties payments payor percent permanent establishment permit posed treaty proposed protocol paragraph proposed treaty contains proposed treaty provides public company test purposes real property reinsurance REMIC resident of Mexico respect royalties saving clause similar source country tax subject to U.S. Tax Law taxable taxes imposed Technical Explanation TIEA tion trade or business trea treaty benefits treaty country treaty's U.S. branch U.S. citizen U.S. corporation U.S. income tax U.S. law U.S. model treaty U.S. person U.S. resident U.S. source income U.S. tax treaties U.S. trade U.S. treaty United withholding tax
Populāri fragmenti
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.
69. lappuse - royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including...
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...
30. lappuse - Hearings Before the Subcommittee on Oversight of the House Committee on Ways and Means, 101st Cong., 2d Sess.