Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Kingdom of the Netherlands: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 27, 1993U.S. Government Printing Office, 1993 - 137 lappuses |
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1.–5. rezultāts no 23.
5. lappuse
... ownership threshold must be met ( either 25 percent stock ownership by one recipient corporation residing in the other country , or 25 percent ownership by a group of recipient corporations resident in that country each of which owns at ...
... ownership threshold must be met ( either 25 percent stock ownership by one recipient corporation residing in the other country , or 25 percent ownership by a group of recipient corporations resident in that country each of which owns at ...
16. lappuse
... on its ulti- 3 The U.S. income tax treaty with Jamaica and the proposed U.S. income tax treaty with Mex- ico would also provide for such benefits , but in a much more limited way . mate ownership by a third country resident who would be 16.
... on its ulti- 3 The U.S. income tax treaty with Jamaica and the proposed U.S. income tax treaty with Mex- ico would also provide for such benefits , but in a much more limited way . mate ownership by a third country resident who would be 16.
17. lappuse
... ownership " requirement ) , the other concerning the destination of payments that it deducts from its income ( the base reduction or " erosion " requirement ) . The ownership requirement in one anti - treaty shopping provision pro ...
... ownership " requirement ) , the other concerning the destination of payments that it deducts from its income ( the base reduction or " erosion " requirement ) . The ownership requirement in one anti - treaty shopping provision pro ...
20. lappuse
... circumstances . ( 2 ) Real property gains Under the Foreign Investment in Real Property Tax Act of 1980 ( FIRPTA ) , a foreign person is taxed by the United States on gain from the sale of direct ownership interests in U.S. real 20.
... circumstances . ( 2 ) Real property gains Under the Foreign Investment in Real Property Tax Act of 1980 ( FIRPTA ) , a foreign person is taxed by the United States on gain from the sale of direct ownership interests in U.S. real 20.
21. lappuse
... ownership interests in U.S. real property as if the gain were effectively connected with a trade or business con- ducted in the United States . Generally , the right of the United States to impose tax on this gain was not restricted ...
... ownership interests in U.S. real property as if the gain were effectively connected with a trade or business con- ducted in the United States . Generally , the right of the United States to impose tax on this gain was not restricted ...
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Bieži izmantoti vārdi un frāzes
alienation amount apply attributable beleggingsinstelling branch profits tax branch tax business profits competent authorities coun country of residence deductible dividend tax double taxation Dutch company Dutch corporation Dutch law Dutch resident Dutch tax earned effectively connected entity establishment or fixed exchange excise tax exemption FIRPTA fixed base foreign corporation foreign person foreign tax credit gain headquarters company income tax treaty independent personal services internal law limitation on benefits Netherlands nonresident nonresident alien payments posed treaty present treaty profit share proposed protocol proposed treaty contains proposed treaty provides purposes reinsurance resi residence country royalties rules source country tax staff understands subject to U.S. tax avoidance taxable taxpayer third country tion trade or business trea treaty benefits treaty country resident U.S. citizens U.S. corporation U.S. income tax U.S. law U.S. model treaty U.S. person U.S. real property U.S. resident U.S. source income U.S. trade U.S. treaties 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.
48. lappuse - The term shall in any case Include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as immovable property.
118. lappuse - Convention. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other...
52. 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.
131. lappuse - State (other than the business of making or managing investments, unless these activities are banking or insurance activities carried on by a bank or insurance company...
47. lappuse - ... the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character...
57. lappuse - ... income that is treated as effectively connected with the conduct of a US trade or business. The...
51. lappuse - State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment . 3.
42. lappuse - ... means any body corporate or any entity which is treated as a body corporate for tax purposes; f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State...
44. lappuse - resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.