Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Kingdom of the Netherlands: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 27, 1993U.S. Government Printing Office, 1993 - 137 lappuses |
No grāmatas satura
1.–5. rezultāts no 71.
3. lappuse
... Dutch resident com- pany with a branch in a third - country tax haven will be entitled to treaty protection against the imposition of U.S. tax , even though the company is also availing itself of the internal law provisions of both the ...
... Dutch resident com- pany with a branch in a third - country tax haven will be entitled to treaty protection against the imposition of U.S. tax , even though the company is also availing itself of the internal law provisions of both the ...
4. lappuse
... company tax . ( 6 ) By contrast with the present treaty , the proposed treaty intro- duces rules for determining when a person is a resident of either the United States or the Netherlands , and hence is entitled to ben- efits under the ...
... company tax . ( 6 ) By contrast with the present treaty , the proposed treaty intro- duces rules for determining when a person is a resident of either the United States or the Netherlands , and hence is entitled to ben- efits under the ...
5. lappuse
... enterprise of one treaty country from the operation of ships or aircraft in inter- national traffic are taxable only ... company ( RIC ) , real estate investment trust ( REIT ) , or Dutch investment organiza- tion ( beleggingsinstelling ) ...
... enterprise of one treaty country from the operation of ships or aircraft in inter- national traffic are taxable only ... company ( RIC ) , real estate investment trust ( REIT ) , or Dutch investment organiza- tion ( beleggingsinstelling ) ...
6. lappuse
... Dutch company that is a beleggingsinstelling , in which case the 15 - percent rate applies , Dutch withholding taxes on dividends from a beleggingsinstelling generally are unrestricted to a similar extent if the beleggingsinstelling ...
... Dutch company that is a beleggingsinstelling , in which case the 15 - percent rate applies , Dutch withholding taxes on dividends from a beleggingsinstelling generally are unrestricted to a similar extent if the beleggingsinstelling ...
8. lappuse
... Dutch resident company if the U.S. resident and relat- ed individuals own 25 percent or more of any class of stock in the Dutch company , and the U.S. resident was a Dutch resident within the previous 5 years . The Netherlands must ...
... Dutch resident company if the U.S. resident and relat- ed individuals own 25 percent or more of any class of stock in the Dutch company , and the U.S. resident was a Dutch resident within the previous 5 years . The Netherlands must ...
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Bieži izmantoti vārdi un frāzes
alienation amount apply attributable beleggingsinstelling branch profits tax branch tax business profits competent authorities coun country of residence deductible dividend tax double taxation Dutch company Dutch corporation Dutch law Dutch resident Dutch tax earned effectively connected entity establishment or fixed exchange excise tax exemption FIRPTA fixed base foreign corporation foreign person foreign tax credit gain headquarters company income tax treaty independent personal services internal law limitation on benefits Netherlands nonresident nonresident alien payments posed treaty present treaty profit share proposed protocol proposed treaty contains proposed treaty provides purposes reinsurance resi residence country royalties rules source country tax staff understands subject to U.S. tax avoidance taxable taxpayer third country tion trade or business trea treaty benefits treaty country resident U.S. citizens U.S. corporation U.S. income tax U.S. law U.S. model treaty U.S. person U.S. real property U.S. resident U.S. source income U.S. trade U.S. treaties United withholding tax