Explanation of Proposed Income Tax Treaty Between the United States and the Slovak Republic: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 27, 1993U.S. Government Printing Office, 1993 - 58 lappuses Distributed to some depository libraries in microfiche. |
No grāmatas satura
1.–5. rezultāts no 11.
3. lappuse
... avoid double taxation and to prevent fiscal evasion with re- spect to income taxes ( Articles 26 and 27 ) . Differences between proposed treaty and other treaties The proposed treaty differs in certain respects from other U.S. income ...
... avoid double taxation and to prevent fiscal evasion with re- spect to income taxes ( Articles 26 and 27 ) . Differences between proposed treaty and other treaties The proposed treaty differs in certain respects from other U.S. income ...
9. lappuse
... avoid double taxation . In no event , however , would the tax paid to the United States be less than the tax that would be paid if the individual were not a U.S. citizen . ( 27 ) Under the proposed treaty's mutual agreement procedure ...
... avoid double taxation . In no event , however , would the tax paid to the United States be less than the tax that would be paid if the individual were not a U.S. citizen . ( 27 ) Under the proposed treaty's mutual agreement procedure ...
16. lappuse
... avoid all U.S. tax liabil- ity for such year so long as it had sufficient foreign tax credits and no domestic income ( whether or not the taxpayer had economic in- come from domestic operations ) . In order to mandate at least a nominal ...
... avoid all U.S. tax liabil- ity for such year so long as it had sufficient foreign tax credits and no domestic income ( whether or not the taxpayer had economic in- come from domestic operations ) . In order to mandate at least a nominal ...
19. lappuse
... avoid U.S. tax . To prevent third - country residents from obtaining treaty benefits intended for treaty country residents only , the treaties generally contain an " anti - treaty shopping " provision that is designed to limit treaty ...
... avoid U.S. tax . To prevent third - country residents from obtaining treaty benefits intended for treaty country residents only , the treaties generally contain an " anti - treaty shopping " provision that is designed to limit treaty ...
23. lappuse
... avoided by the proposed treaty assigning one of the countries as the coun- try of residence where under the laws of the countries the person is a resident of both . Under U.S. law , residence of an individual is important because a ...
... avoided by the proposed treaty assigning one of the countries as the coun- try of residence where under the laws of the countries the person is a resident of both . Under U.S. law , residence of an individual is important because a ...
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Bieži izmantoti vārdi un frāzes
alimony amount attributable branch profits tax business profits Code section competent authority country of residence deductions dividends paid domestic law double taxation effectively connected enterprise entity establishment or fixed fixed base foreign corporation foreign persons foreign source income foreign tax credit green card income derived income from real income tax treaties independent personal services international traffic nonresident alien passive income payments payor percent period permanent establishment posed treaty proposed treaty contains proposed treaty provides purposes real property REIT REMIC resi resident in Slovakia respect royalties ships or aircraft Slovak crowns Slovak Republic sound reproduction source rules specific spect subject to U.S. tax its citizens taxes paid taxing jurisdiction taxpayer Technical Explanation tion trade or business trea treaty benefits treaty country U.S. citizen resident U.S. corporation U.S. income tax U.S. law U.S. model treaty U.S. person U.S. resident U.S. source income U.S. tax treaties U.S. trade U.S. treaties United
Populāri fragmenti
11. 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.
8. 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...
56. 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).
4. lappuse - dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident.
56. 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.
5. 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 cinematograph films...
23. 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.
21. 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...
20. lappuse - citizen" shall include a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss.
17. lappuse - Treaties generally provide for the exchange of information between the tax authorities of the two countries when such information is necessary for carrying out provisions of the treaty or of their domestic tax laws. The obligation to exchange information under the treaties typically does not require either country to carry out measures contrary to its laws or administrative practices or to supply information...