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 100.
2. lappuse
... country from sources within the other country , and to prevent avoidance or evasion of income taxes of the two ... residence , or , in the case where the Netherlands is the country of residence , allowing in some cases a proportional ...
... country from sources within the other country , and to prevent avoidance or evasion of income taxes of the two ... residence , or , in the case where the Netherlands is the country of residence , allowing in some cases a proportional ...
3. lappuse
... 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 third ...
... 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 third ...
4. lappuse
... country to reduce taxes on all U.S. citizens , regardless of where they reside . The United States frequently has been unable to negotiate cov- erage for nonresident citizens in its income tax treaties . Exceptions include treaties with ...
... country to reduce taxes on all U.S. citizens , regardless of where they reside . The United States frequently has been unable to negotiate cov- erage for nonresident citizens in its income tax treaties . Exceptions include treaties with ...
5. lappuse
... country may tax an enterprise resident in that country on profits that were , by virtue of its participation in the management or the financial structure of an enterprise of the other treaty coun- try , reduced by non - arm's - length ...
... country may tax an enterprise resident in that country on profits that were , by virtue of its participation in the management or the financial structure of an enterprise of the other treaty coun- try , reduced by non - arm's - length ...
6. lappuse
... resident holding a less than 25 - percent interest in the REIT , or by a Dutch company that is a beleggingsinstelling ... country taxation on interest ( including the branch level tax on excess interest deductions ) , the proposed treaty ...
... resident holding a less than 25 - percent interest in the REIT , or by a Dutch company that is a beleggingsinstelling ... country taxation on interest ( including the branch level tax on excess interest deductions ) , the proposed treaty ...
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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