Hearings, Reports and Prints of the Senate Committee on Foreign RelationsU.S. Government Printing Office, 1971 |
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Page 14
... derived from motion picture films , films or tapes of radio or television broad- casting and , hence , under this provision , there will be no tax in Finland as long as the American motion picture company has no permanent establishment ...
... derived from motion picture films , films or tapes of radio or television broad- casting and , hence , under this provision , there will be no tax in Finland as long as the American motion picture company has no permanent establishment ...
Page 15
... derived by the American company . There would , however , be an American tax on the worldwide income . So by relieving the American motion picture firm from Finnish tax in that case , our revenues would be increased because we would not ...
... derived by the American company . There would , however , be an American tax on the worldwide income . So by relieving the American motion picture firm from Finnish tax in that case , our revenues would be increased because we would not ...
Page 16
... derived . It has been difficult to resolve these questions in advance . At times it depends upon the law in the country to which the prop- erty is transferred . It is particularly important that the possibility of a tax - free transfer ...
... derived . It has been difficult to resolve these questions in advance . At times it depends upon the law in the country to which the prop- erty is transferred . It is particularly important that the possibility of a tax - free transfer ...
Page 29
... derived from sources in Trinidad and Tobago by a resident of the United States which is a bank or other financial institution not having a permanent establishment in Trinidad and Tobago will be subject to Trinidad withholding at a ...
... derived from sources in Trinidad and Tobago by a resident of the United States which is a bank or other financial institution not having a permanent establishment in Trinidad and Tobago will be subject to Trinidad withholding at a ...
Page 35
... derived from sources within the country of residence of the payor . The normal rule under our tax laws is that this type of income has its source in the country in which the property right is used . The present exemption from source ...
... derived from sources within the country of residence of the payor . The normal rule under our tax laws is that this type of income has its source in the country in which the property right is used . The present exemption from source ...
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Common terms and phrases
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.