Hearings, Reports and Prints of the Senate Committee on Foreign RelationsU.S. Government Printing Office, 1971 |
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agreement allowed Ambassador YOST Amchitka Island American amount apply Belgian Belgium business profits CHAIRMAN citizen COHEN commercial profits Committee competent authorities continental shelf decedent derived dividends domicile double taxation earthquake effectively connected estate tax exempt from tax existing convention explosion Finland Finnish foreign tax credit Hickenlooper amendment income tax treaties industrial or commercial interest Internal Revenue Code investment Latin America LILLICH limited ment Netherlands Nevada nonresident nuclear tests OECD Model Convention percent permanent establishment personal services Peru Peruvian Pitzer political present problem proposed convention provides purposes question real property recipient recognition resident respect royalties Secretary section 351 seismic Senator AIKEN Senator CHURCH Senator GRAVEL source country source rule statement tax imposed taxable term tion Tobago corporation Trinidad and Tobago tsunami U.S. income tax U.S. military U.S. tax underground nuclear United Nations United States tax withholding tax WOODWORTH
Popular passages
Page 43 - New World, have been treated by the United States as questions of fact only, and our predecessors have cautiously abstained from deciding upon them until the clearest evidence was in their possession to enable them not only to decide correctly, but to shield their decisions from every unworthy imputation.
Page 98 - permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment...
Page 1 - (c) The Secretary shall designate one of the members to serve as Chairman and one to serve as Vice Chairman of the Council.
Page 2 - (A) appoint and fix the compensation of an executive director, and such additional staff personnel as he deems necessary, without regard to the provisions of title 5, United States Code, governing appointments in the competitive service...
Page 1 - CHANGES IN EXISTING LAW MADE RY THE BILL, AS REPORTED In compliance with clause 3 of rule XIII of the Rules of the House of Representatives, changes in existing law made by the bill, as reported, are shown as follows (existing law proposed to be omitted is enclosed in black brackets, new matter is printed in italic...
Page 1 - CHANGES IN EXISTING LAW In compliance with subsection (4) of rule XXIX of the Standing Rules of the Senate, changes in existing law made by the bill, as reported, are shown as follows (existing law proposed to be omitted is enclosed in black brackets, new matter is printed in italic, existing law in which no change is proposed is shown in roman...
Page 94 - States as determined under the provisions of this part; but only in an amount which bears the same ratio to such dividends as the gross income of the corporation for such period derived from sources within the United States bears to its gross income from all sources...
Page 115 - Party's tax attributable to the same property, whichever is the less, as the former amount bears to the sum of both amounts. (3...
Page 2 - Commission. (i) There are hereby authorized to be appropriated such sums as may be necessary to carry out the provisions of this section. (j) On the ninetieth day after the' date of submission of its final report to the President, the Workmen's Compensation Commission shall cease to exist.
Page 96 - competent authority" means: i) In the case of the United States, the Secretary of the Treasury or his delegate, and ii) In the case of the Netherlands, the Minister of Finance or his duly authorized representative.