...that trade or business. However, this exception does not apply (and benefits are therefore denied) to the business of making or managing investments, unless...activities carried on by a bank or insurance company. This active trade or business rule replaces a more general rule in the US model treaty and some other...

...that trade or business. However, this exception does not apply (and benefits are therefore denied) to the business of making or managing investments, unless...activities carried on by a bank or insurance company. This active trade or business rule replaces a more general rule in the US model treaty and some other...

...connection with, or is incidental to, the active conduct by such person of a trade or business in that State (other than the business of making or managing investments, unless these activities are carried on by a bank or insurance company); "(c) the person deriving the income is a company which...

...treaty benefits is thus subject to the ownership/"base erosion" and disproportionate-ownership tests) to the business of making or managing investments, unless...activities carried on by a bank or insurance company. This active trade or business rule replaces a more general rule in some earlier US income tax treaties...

...that trade or business. However, this exception does not apply (and benefits are therefore denied) to the business of making or managing investments, unless...activities carried on by a bank or insurance company. This active trade or business rule replaces a more general rule in some earlier US income tax treaties...

...making or managing investments generally would not qualify as an active trade or business unless the activities are banking or insurance activities carried on by a bank or insurance company. This active trade or business rule differs from a more general rule in some earlier US income tax treaties...

...active conduct of a trade or business carried on by the permanent establishment in the third country (other than the business of making or managing investments...activities carried on by a bank or insurance company). According to the Technical Explanation, the competent authority would grant relief in a case where...

...(and therefore is not eligible to claim treaty benefits under this rule) by virtue of being engaged in the business of making or managing investments, unless...activities carried on by a bank or insurance company. The active trade or business rule is consistent with similar tests in recent US treaties, and replaces...

...active conduct of a trade or business carried on by the permanent establishment in the third country (other than the business of making or managing investments unless these activities are banking or insurance carried on by a bank or insurance company). Article 24. Relief from Double Taxation US internal law...

...or (d) engaged in the active conduct of a trade or business in the firstmentioned Contracting State (other than the business of making or managing investments,...banking or insurance activities carried on by a bank insurance company), and the income derived from the other Contracting State is derived in connection...