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" 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... "
The Breakdown of IRS Tax Enforcement Regarding Multinational Corporations ... - 82. lappuse
autors: United States. Congress. Senate. Committee on Governmental Affairs - 1993 - 341 lapas
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Conventions with Great Britain and Northern Ireland Respecting Income and ...

United States. Congress. Senate. Foreign Relations - 1945 - 94 lapas
...which would be made with an independent enterprise, any profits which would but for those conditions have accrued to one of the enterprises, but by reason...profits of that enterprise and taxed accordingly. Hence, the Treasury now has recognition of its powers under section 45 to assure the proper allocation...
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Income and Estate Tax Conventions

United States. Congress. Senate. Committee on Foreign Relations - 1945 - 138 lapas
...which would be made with an independent enterprise, any profits which would but for those conditions have accrued to one of the enterprises but by reason...profits of that enterprise and taxed accordingly. ARTICLE v (1) Notwithstanding the provisions of Articles III and IV of the present Convention, profits...
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Individual Income Tax Provisions of the Internal Revenue Code: Applicable to ...

United States. Congress. Joint Committee on Internal Revenue Taxation - 1946 - 428 lapas
...which would be made with an independent enterprise, any profits which would but for those conditions have accrued to one of the enterprises but by reason...profits of that enterprise and taxed accordingly. Article V (1) Notwithstanding the provisions of Articles III and IV of the present Convention, profits...
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The Code of Federal Regulations of the United States of America

2001 - 228 lapas
...different from those which would be made with an independent enterprise, any profits which would normally have accrued to one of the enterprises, but by reason...profits of that enterprise and taxed accordingly. ARTICLE V Income which an enterprise of one of the contracting States derives from the operation of...
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The Code of Federal Regulations of the United States of America

1974 - 436 lapas
...from those which would be made with an Independent enterprise, any profits which would normally nave accrued to one of the enterprises but by reason of...profits of that enterprise and taxed accordingly. (1) Income which an enterprise of one of the contracting States derives from the §511.101 operation...
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United States Treaties and Other International Agreements, 5. sējums

United States - 1954 - 830 lapas
...differing from those which would be nade with an Independent enterprise, any profits which would normally have accrued to one of the enterprises, but by reason...profits of that enterprise and taxed accordingly. Article V Profits derived by an enterprise of one of the contractIng States from the operation of ships...
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Statutory Instruments, 3. daļa

Great Britain - 1961 - 1446 lapas
...would be made between independent enterprises, any profits, which would, out for those conditions, have accrued to one of the enterprises but by reason...profits of that enterprise and taxed accordingly. ARTICLE V (1) Notwithstanding the provisions of Articles III and IV, profits derived by a resident...
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Investment in India: Basic Information for United States Businessmen

United States. Bureau of Foreign Commerce. Far Eastern Division, Celia I. Herman - 1961 - 286 lapas
...which would be made between independent enterprises, then any profits which but for those conditions would have accrued to one of the enterprises but by...profits of that enterprise and taxed accordingly. ARTICLE V Income derived by an enterprise of one of the territories from the operation of aircraft...
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Legislative History of United States Tax Conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 1516 lapas
...conditions different from those which would be made with an independent enterprise, any profits which would have accrued to one of the enterprises but by...profits of that enterprise and taxed accordingly. ARTICLE V (1) Notwithstanding the provisions of Articles III and IV of the present Convention, profits...
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Legislative History of United States Tax Conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 1532 lapas
...different from those which would be made with an independent enterprise, any profits which would normally have accrued to one of the enterprises but by reason...profits of that enterprise and taxed accordingly. ARTICLE V (1) Income which an enterprise of one of the contracting States derives from the operation...
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