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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. "
Explanation of Proposed Income Tax Treaty Between the United States and the ... - 23. lappuse
1993 - 58 lapas
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The Code of Federal Regulations of the United States of America

1998 - 794 lapas
...of the treaty provides that for purposes of the treaty, a " ' 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, place of Incorporation, or any other criterion of a similar...
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The Code of Federal Regulations of the United States of America

1998 - 808 lapas
...of the treaty provides that for purposes of the treaty, a " '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, place of Incorporation, or any other criterion of a similar...
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Tax Treaties: Hearing Before the Committee on Foreign Relations, United ...

United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 lapas
...purposes of the Convention. Paragraph l provides that the term "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, place of incorporation, or any other criterion of a similar...
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United States Congressional Serial Set

1987 - 948 lapas
...ARTICLE 4: RESIDENT 1. For purposes of this Convention, the term "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, citizenship, place of management, place of incorporation, or any other criterion...
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Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between ...

1983 - 52 lapas
...in the United States if it is organized in 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 subject to tax therein by reason of his domicile, residence, citizenship, place of management, place...
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Explanation of proposed income tax treaty (and proposed protocol) between ...

United States. Congress. Joint Committee on Taxation - 1984 - 68 lapas
...in the United States if it is organized in the United States. The proposed treaty generally defines "resident of a Contracting State" to mean any person...that State, is liable to tax therein by reason of his domicile, residence, citizenship, place of incorporation, or any other criterion of a similar nature....
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Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between ...

1985 - 68 lapas
...benefits residents, rather than citizens, of the United States.) The proposed treaty generally defines "resident of a Contracting State" to mean any person who, under the laws of that country, is liable to tax therein by reason of his domicile, residence, citizenship, place of incorporation,...
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Congressional Serial Set

1992 - 858 lapas
...Residence ]. For the purposes of this Convention, the tern "resident o* a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his coricile, residence, place of nanagencnt, place of incorporation, or any other criterion of a sinilar...
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Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between ...

1993 - 72 lapas
...laws of the United tut es. a State, or the District of Columbia. The proposed treaty generally defines "resident of a Contracting State" to mean any person who, under the laws of that country, is liable to tax therein by reason of his domicile, residence, citizenship, place of incorporation,...
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Doppelbesteuerungsabkommen

W. Gassner - 1997 - 290 lapas
...in Article 4 OECD Model. Article 4 OECD Model states that a '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. This term does,...
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