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Administration amount annuities application August 11 Austria citizen commercial profits Commissioner of Internal competent authorities contracting date delayed date was delayed delayed until Jan dends Department derived from sources domestic corporation engaged in trade entity excess tax withheld exempt from United Federal Federal Acquisition Regulation fiduciary filed foreign corporation Form gross income income tax Internal Revenue Code Internal Revenue Service Ireland Irish tax items of income January letter of notification ment nent establishment nonresident alien individual notify the withholding Office owner Pakistan paragraph payment permanent establishment poration present Convention provisions of Article rate of tax real property reduced rate Regulation at 62 rentals resi resident of France respect royalties spect Sweden Swedish Swiss corporation tax at source tax was withheld taxable years beginning taxation taxpayer tion tracting trade or business U.S. tax United States corporation United States dollars United States tax vention withholding agent withholding of United
Page 68 - Convention by a Contracting State any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of the Convention. Article 4 Fiscal domicile 1. For the purposes of this Convention, the term " resident of a Contracting State...
Page 79 - interest" as used in this Article means income from Government securities, bonds or debentures, whether or not secured by mortgage and whether or not carrying a right to participate in profits, and debt-claims of every kind as well as all other income assimilated to income from money lent by the taxation law of the State in which the income arises.
Page 91 - June 6, 1932, the compensation received as such shall be included in gross income. (b) Exclusions from gross income. The following items shall not be included in gross income and shall be exempt from taxation under this chapter: (1) Life insurance.
Page 173 - Advisory Council on Historic Preservation African Development Foundation Federal Acquisition Regulation Agency for International Development, United States Federal Acquisition Regulation Agricultural Marketing Service Agricultural Research Service Agriculture Department Agricultural Marketing Service Agricultural Research Service Animal and Plant Health Inspection Service Chief Financial Officer, Office of Commodity Credit Corporation Cooperative State Research, Education, and Extension Service Economic...
Page 111 - In the application of the provisions of the present Convention by one of the contracting States, any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that contracting State relating to the taxes which are the subject of the present Convention.
Page 23 - Convention or for the prevention of fraud or the like in relation to the taxes which are the subject of the present Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or any trade process.
Page 140 - State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions have accrued to one of the enterprises, but by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Page 33 - ARTICLE xvni (1) The provisions of this Convention shall not be construed to deny or affect in any manner the right of diplomatic and consular officers to other or additional exemptions now enjoyed or which may hereafter be granted to such officers.
Page 143 - The provisions of the present Convention shall not be construed to restrict in any manner any exemption, deduction, credit or other allowance now or hereafter accorded by the laws of one of the contracting States in the determination of the tax imposed by such State.