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 58.
5. lappuse
... company ( RIC ) , real estate investment trust ( REIT ) , or Dutch investment organiza- tion ( beleggingsinstelling ) . ) ( 14 ) Under the present treaty , the prohibition on source country tax on direct investment dividends exceeding 5 ...
... company ( RIC ) , real estate investment trust ( REIT ) , or Dutch investment organiza- tion ( beleggingsinstelling ) . ) ( 14 ) Under the present treaty , the prohibition on source country tax on direct investment dividends exceeding 5 ...
6. lappuse
... Dutch resident holding a less than 25 - percent interest in the REIT , or by a Dutch company that is a beleggingsinstelling , in which case the 15 - percent rate applies , Dutch withholding taxes on dividends from a beleggingsinstelling ...
... Dutch resident holding a less than 25 - percent interest in the REIT , or by a Dutch company that is a beleggingsinstelling , in which case the 15 - percent rate applies , Dutch withholding taxes on dividends from a beleggingsinstelling ...
7. lappuse
... business profits under the proposed treaty ( Article 7 ) . Under the present ... Dutch residents to third - country residents , even if under the Code , such ... corporate reorganization or other case where a resident of the other country ...
... business profits under the proposed treaty ( Article 7 ) . Under the present ... Dutch residents to third - country residents , even if under the Code , such ... corporate reorganization or other case where a resident of the other country ...
8. lappuse
... Dutch company , and the U.S. resident was a Dutch resident within the previous 5 years . The Netherlands must allow a foreign tax credit for U.S. tax in such a case . The treaty gives the United States reciprocal taxation rights in this ...
... Dutch company , and the U.S. resident was a Dutch resident within the previous 5 years . The Netherlands must allow a foreign tax credit for U.S. tax in such a case . The treaty gives the United States reciprocal taxation rights in this ...
11. lappuse
... Dutch company in which the U.S. company owns sufficient voting stock . • Under the proposed treaty , unlike the present treaty , the Netherlands state share in the profit from exploi- tation of natural resources is treated as a covered ...
... Dutch company in which the U.S. company owns sufficient voting stock . • Under the proposed treaty , unlike the present treaty , the Netherlands state share in the profit from exploi- tation of natural resources is treated as a covered ...
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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