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 12.
2. lappuse
... tax income derived by residents of the other country , the treaty generally would provide for the relief of the potential double taxation generally by requiring the other coun- try to grant a credit against its tax for the taxes paid to ...
... tax income derived by residents of the other country , the treaty generally would provide for the relief of the potential double taxation generally by requiring the other coun- try to grant a credit against its tax for the taxes paid to ...
6. lappuse
... tax in certain cases . The rate of that tax could not exceed 5 per- cent . The United States would be allowed under the ... foreign tax credit under the article on relief from double taxation ( Article 24 ) . The special sourcing provi ...
... tax in certain cases . The rate of that tax could not exceed 5 per- cent . The United States would be allowed under the ... foreign tax credit under the article on relief from double taxation ( Article 24 ) . The special sourcing provi ...
16. lappuse
... credit their foreign income taxes against the U.S. tax imposed on their foreign source income . A fundamental premise of the foreign tax credit is that it may not offset the U.S. tax on U.S. source income . Therefore , the foreign tax ...
... credit their foreign income taxes against the U.S. tax imposed on their foreign source income . A fundamental premise of the foreign tax credit is that it may not offset the U.S. tax on U.S. source income . Therefore , the foreign tax ...
17. lappuse
... taxation can result . Problems sometimes arise in the deter- mination of whether a foreign tax qualifies for the U.S. foreign tax credit . Also , double taxation may arise in situations were a corpora- tion or individual may be treated ...
... taxation can result . Problems sometimes arise in the deter- mination of whether a foreign tax qualifies for the U.S. foreign tax credit . Also , double taxation may arise in situations were a corpora- tion or individual may be treated ...
18. lappuse
... taxation also may arise , notwithstanding the existence of a treaty , because most countries will not exempt passive income from tax at the source . Double taxation is further mitigated either by granting a credit for income taxes paid ...
... taxation also may arise , notwithstanding the existence of a treaty , because most countries will not exempt passive income from tax at the source . Double taxation is further mitigated either by granting a credit for income taxes paid ...
Citi izdevumi - Skatīt visu
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...