International Double Taxation: Hearings, Seventy-first Congress, Second Session on H.R. 10165, February 28 and March 1, 1930U.S. Government Printing Office, 1930 - 50 lappuses |
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administrative agree agreement alien American citizen American corporation American tax amount apply arrangements BACHARACH basis bill bonds Britain British capital cent CHAIRMAN collect committee concerned conference Congress consider corporation correct course deal deduction determined dividends Doctor ADAMS dollar double taxation effect encourage England establishment ESTEP European exempt fact followed foreign country France GARNER give going Government imposed income income tax individual instance interest investments abroad Italy kind legislation live matter mean ment method MILLS mind months nonresident opinion paid particular permanent practical present principle proposed provisions question RAMSEYER rates reasons received reciprocal reference regard represented residence respect revenue Secretary MELLON securities situation statement Suppose surtax taxable taxpayer thing tion Treasury Department treaty true understand United unless withholding
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2. lappuse - But the fact that an enterprise of one of the contracting States has business dealings in the other State through a bona fide commission agent or broker shall not be held to mean that such enterprise has a permanent establishment in the latter State.
9. lappuse - The income of a nonresident alien individual which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States, shall not be included in gross income and shall be exempt from taxation under this title.
9. lappuse - States as consists of earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States nonresident in such foreign country and to corporations organized in the United States, shall not be included in gross income.
2. lappuse - Mellon, in the report of the Secretary of the Treasury for the fiscal year ended June 30...
2. lappuse - Intended, terms used in this Act shall have the same meaning as when used in the Internal Revenue Code...
29. lappuse - Parties with respect to the interpretation or application of the provisions of the present Convention shall be subject to negotiation between the Parties involved in the dispute. 2. If the dispute cannot be resolved in accordance with paragraph 1 of this Article, the Parties may, by mutual consent, submit the dispute to arbitration...
19. lappuse - States by such a corporation or such a citizen, or by a corporation created or organized in, or under the law of, a possession of the United States...
1. lappuse - 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, trade-marks, trade brands, franchises, and other like property; and (5) Gains, profits, and income from the sale of real property located in the United States.
29. lappuse - Income from any industrial, commercial, or agricultural undertaking, and from any other trades or professions not referred to in paragraph D, shall be taxable in the State in which a permanent establishment is situated. The real centers of management, branches, mining and oil-fields, factories, workshops, agencies, warehouses, offices, depots, shall be regarded as permanent establishments.
29. lappuse - ... before resorting to any arbitral or judicial procedure, submit the dispute, with a view to an amicable settlement, to such technical body as the Council of the League of Nations may appoint for this purpose. This body will give an advisory opinion after hearing the parties...