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accordance activities addition agreement alien allow amount apply Article attributable basis benefits business profits capital carried certain Code competent authority conduct coun deductions derived described determined dividends double taxation earnings effectively connected enterprises entity example excess exchange exemption extent fixed base foreign corporation foreign tax credit gains gross imposed income tax treaties independent individual interest internal law investment jurisdiction less limitation means ment nonresident OECD model treaties operation paid payments percent performed period permanent establishment permit personal services portion posed present profits tax prohibits proposed protocol proposed treaty provides real property received requires resident respect restriction royalties rules Russian ships similar situated source country specific taking taxable taxpayers Technical term third tion trade or business trea treatment treaty benefits treaty contains treaty country U.S. citizens U.S. model treaty U.S. tax United unless unlike USSR treaty withholding tax
14. 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.
57. lappuse - Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more...
58. lappuse - State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
35. lappuse - ... income that is treated as effectively connected with the conduct of a US trade or business. The...
59. lappuse - State; c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
15. lappuse - Hearings Before the Subcommittee on Oversight of the House Committee on Ways and Means, 101st Cong., 2d Sess.
42. lappuse - royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including...
25. lappuse - But 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 or capital situated therein.