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" State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned; (b) The remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) The remuneration is not borne by a permanent... "
Internal Revenue Bulletin: Cumulative bulletin - Page 700
by United States. Internal Revenue Service - 1968
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Model tax conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 724 pages
...exercised in the other Contracting State shall be taxable only in the first mentioned State if: a) the recipient is present in the other State for a...the aggregate 183 days in the fiscal year concerned, and b) the remuneration is paid by, or on behalf of an employer who is not a resident of the other...
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Internal Revenue Cumulative Bulletin, Issue 2

United States. Internal Revenue Service - 1975 - 652 pages
...employment exercise in the other Contracting State shall not be taxable in such other State if: (a) The recipient is present in the other State for a...concerned, (b) The remuneration is paid by or on behalf of the employer who is not a resident of the other State, and (c) The remuneration is not borne by a permanent...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1971 - 816 pages
...in respect of independent activities pershall be exempt from tax by that other Contracting State if the recipient is present in the other State for a...the aggregate 183 days in the fiscal year concerned. ARTICLE 19 DEPENDENT PERSONAL SERVICES 1 . Salaries, wages, and other similar remuneration paid to...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1977
...that other Contracting State for a period or periods aggregating less than 183 days during the taxable d d d Y d d d d d d d d d d c c c c c c cXdYdZd c c c cTdUd c c c c c c c cod~` d c1^ c d c c c E d d d c d d d Contracting State; and (c) the remuneration is not borne as such by a permanent establishment which...
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Internal Revenue Cumulative Bulletin, Issue 1

United States. Internal Revenue Service - 1975 - 804 pages
...Contracting State shall not be taxable in such other State if: (1) the recipient is present in such 4 ^ g +&L3 :3 ZT zVn5 a ;- R ,`D_ 8DA p , Y & d 28 ]+ b E @ k and (2) the recipient does not maintain a fixed base in the other State for a period or periods exceeding...
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Tax Conventions with Belgium, Finland, Trinidad and Tobago, and the ...

United States. Congress. Senate. Committee on Foreign Relations - 1971 - 196 pages
...(1) the individual is not present in the source country for more than 183 days during the year; (2) the remuneration is paid by, or on behalf of, an employer who is not a resident of the source country; and (3) the remuneration is not borne by a permanent establishment of the employer...
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Legal Problems of Caribbean Integration: A Study on the Legal Aspects of Caricom

Hans Jörg Geiser, Pamela Alleyne, Carroll Gajraj - 1976 - 298 pages
...Schedule 2 State for a period or periods not exceeding in the aggregate 183 days in the tax year; and (b) the remuneration is paid by or on behalf of an employer who is not a resident of the Schedule 2 State ; and (c) the remuneration is not deducted from the profits of a permanent establishment...
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Tax Treaties: Hearing Before the Committee on Foreign Relations, United ...

United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 pages
...recipient is present in the other Contracting State for not more than l83 days in the taxable year, he is paid by or on behalf of an employer who is not a resident of the other State, and the remuneration is not borne as a deduction by a permanent establishment or fixed base of the employer...
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United States Congressional Serial Set

1987 - 948 pages
...for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; (c) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (d) such remuneration is not borne by a permanent establishment or regular base which the employer...
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Congressional Serial Set

1992 - 858 pages
...exercised in the other Contracting State shall be taxable only in the first-mentioned State if (a) the recipient is present in the other State for a...periods not exceeding in the aggregate 183 days in any 12 month period; (b) the remuneration is paid by, or on behalf of, an employer who is not a resident...
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