 | 1983 - 52 lapas
...nature. However, the term "resident of a Contracting State" does not include any person who is subject to tax in that country in respect only of income from sources in that country, nor does it include a person who is subject to tax in that country by reason of citizenship but who... | |
 | 1987 - 948 lapas
...of incorporation, or any other criterion of a similar nature, provided, however, that (a) this term does not include any person who is liable to tax in that State in respect only of income from sources in that State; and (b) in the case of income derived or... | |
 | United States. Congress. Joint Committee on Taxation - 1984 - 68 lapas
...incorporation, or any other criterion of a similar nature. However, the term "resident of a Contracting State" does not include any person who is liable to tax in...respect only of income from sources in that country. This provision of the proposed treaty is generally based on the fiscal domicile article of the US model... | |
 | 1990 - 84 lapas
...incorporation, or any other criterion of a similar nature. However, the term "resident of a Contracting State" does not include any person who is liable to tax in...respect only of income from sources in that country. In addition, a US citizen or US green card holder is a US resident only if the person has a substantial... | |
 | 1990 - 100 lapas
...incorporation, or any other criterion of a similar nature. However, the term "resident of a Contracting State" does not include any person who is liable to tax in...country in respect only of income from sources in, or capital situated within, that country. A partnership, estate, or trust will be considered to be... | |
 | 1992 - 858 lapas
...of incorporation, or any other criterion of a sinilar nature, provided, houever, that a! this tern does not include any person who is liable to tax in that State in respect only of incone fron sources in that State or capital situated therein; and b : in... | |
 | 1993 - 72 lapas
...incorporation, or any other criterion of a similar nature. However, the term "resident of a Contracting State" does not include any person who is liable to tax in...country in respect only of income from sources in, or capital situated within, that country. In the case of income derived by a partnership, estate, or... | |
 | 1993 - 116 lapas
...similar nature. The term "resident of a Contracting State" does not include, however, any person that is liable to tax in that country in respect only of income from sources in that country.42 The proposed protocol (paragraph 2) provides that Mexico would consider a US citizen or... | |
 | United States. Congress. Joint Committee on Taxation - 1997 - 78 lapas
...used in treaty "tie-breaker" rules, as described below. The term "resident of a Contracting State" does not include any person who is liable to tax in...country. In the case of income derived by, or paid by, a partnership, estate or trust, the term applies only to the extent that the income it derives is subject... | |
 | 1997 - 80 lapas
...used in treaty "tie-breaker" rules, as described below. The term "resident of a Contracting State" does not include any person who is liable to tax in...respect only of income from sources in that country or of capital situated in that country. In the case of income derived by a partnership, estate, or... | |
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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. 
