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 15.
6. lappuse
... income from a profit- sharing bond . There is no similar provision in the present treaty or the U.S. or OECD models . The internal laws of both the Nether- lands and the United States ( under a provision added to the Code in the Omnibus ...
... income from a profit- sharing bond . There is no similar provision in the present treaty or the U.S. or OECD models . The internal laws of both the Nether- lands and the United States ( under a provision added to the Code in the Omnibus ...
11. lappuse
... share in the profit from exploi- tation of natural resources is treated as a covered tax and will be treated as a creditable income tax for U.S. foreign tax credit purposes . The profit share applies to income from the extraction of oil ...
... share in the profit from exploi- tation of natural resources is treated as a covered tax and will be treated as a creditable income tax for U.S. foreign tax credit purposes . The profit share applies to income from the extraction of oil ...
22. lappuse
... profit share Under the proposed treaty , the share of the Dutch government in profits from exploiting Dutch natural resources such as oil and gas will be treated as an income tax and creditable for U.S. tax purposes , subject to special ...
... profit share Under the proposed treaty , the share of the Dutch government in profits from exploiting Dutch natural resources such as oil and gas will be treated as an income tax and creditable for U.S. tax purposes , subject to special ...
23. lappuse
... income subject to the profit share that is derived from Dutch sources , determined under U.S. prin- ciples . There may be some uncertainty whether the language of the proposed treaty makes this intention clear . If so , the Committee ...
... income subject to the profit share that is derived from Dutch sources , determined under U.S. prin- ciples . There may be some uncertainty whether the language of the proposed treaty makes this intention clear . If so , the Committee ...
31. lappuse
... share of multinational income . 16 Some prefer a so - called " formulary apportionment , ” which can take a variety of forms . The general thrust of formulary apportionment is to first measure total profit of a person or group of ...
... share of multinational income . 16 Some prefer a so - called " formulary apportionment , ” which can take a variety of forms . The general thrust of formulary apportionment is to first measure total profit of a person or group of ...
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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.