 | 1998 - 808 lapas
...derived by such partnership is subject to tax in that State as the Internal Revenue Service, Treasury Income of a resident, either in its hands or In the...relating to income paid or derived through a partnership. (11) Analysis. A may not claim, based on its own status, the benefit of any Income tax treaty since... | |
 | 1998 - 804 lapas
...US-X treaty does not include a provision relating to Income paid or derived through a partnership. Article 12 of the US-Y treaty provides that "royalties...incorporation, or any other criterion of a similar nature * * *". Article 4.2 of the US-Y treaty provides that in the case of income "derived or paid by a partnership... | |
 | 1999 - 834 lapas
...US-X treaty does not include a provision relating to income paid or derived through a partnership. Article 12 of the US-Y treaty provides that "royalties...incorporation, or any other criterion of a similar nature * * *". Article 4.2 of the US-Y treaty provides that in the case of income "derived or paid by a partnership... | |
 | 1998 - 794 lapas
...Contracting State shall not exceed 5 percent of the gross amount thereof * * *". Article 4.1 of the treaty provides that for purposes of the treaty, a...Incorporation, or any other criterion of a similar nature * * * ". Article 4.2 of the treaty provides that In the case of Income derived or paid by a partnership... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 lapas
...laws of a Contracting State to determine residence, consisting of domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. Thus, a US citizen living in a third country would be treated as a resident of the United States for... | |
 | 1987 - 948 lapas
...are the subject of the Convention. ARTICLE 4: RESIDENT 1. For purposes of this Convention, the term "resident of a Contracting State" means any person...tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature,... | |
 | 1983 - 52 lapas
...the laws of that State, is subject to tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. However, the term "resident of a Contracting State" does not include any person who is subject to tax... | |
 | United States. Congress. Joint Committee on Taxation - 1984 - 68 lapas
...the United States. The proposed treaty generally defines "resident of a Contracting State" to mean any person who, under the laws of that State, is liable...tax therein by reason of his domicile, residence, citizenship, place of incorporation, or any other criterion of a similar nature. However, the term... | |
 | 1985 - 68 lapas
..."resident of a Contracting State" to mean any person who, under the laws of that State, is subject to tax therein by reason of his domicile, residence,...incorporation, or any other criterion of a similar nature. However, the term "resident of a Contracting State" does not include any person who is subject to tax... | |
 | 1999 - 68 lapas
...country, is liable to tax in that country by reason of the person's residence, domicile, citizenship, place of management, place of incorporation, or any other criterion of a similar nature. The term "resident of a Contracting State" does not include any person that is liable to tax in that country... | |
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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. 
