Hearings, Reports and Prints of the Senate Committee on Foreign RelationsU.S. Government Printing Office, 1971 - Legislative hearings |
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Page 20
... recipient cor- poration be at least 80 % controlled by the transferor , or the transferor and other transferors , as provided under section 351 . ( 3 ) While section 351 applies to the transfer of any type of " property , " Article 7 ...
... recipient cor- poration be at least 80 % controlled by the transferor , or the transferor and other transferors , as provided under section 351 . ( 3 ) While section 351 applies to the transfer of any type of " property , " Article 7 ...
Page 27
... recipient's country . The treaties ( other than the one with Trinidad and Tobago ) provide exemption for capital gains for a resident of the other country . The conditions for the exemption differ somewhat in the Finnish and Belgian ...
... recipient's country . The treaties ( other than the one with Trinidad and Tobago ) provide exemption for capital gains for a resident of the other country . The conditions for the exemption differ somewhat in the Finnish and Belgian ...
Page 28
... recipient corporation owned 10 percent or more of the vot- ing stock of the paying corporation , the rate was limited to 5 percent . Under the proposed treaty Trinidad will reduce its rates of withholding tax on dividends from the ...
... recipient corporation owned 10 percent or more of the vot- ing stock of the paying corporation , the rate was limited to 5 percent . Under the proposed treaty Trinidad will reduce its rates of withholding tax on dividends from the ...
Page 34
... recipient has a 10 percent ownership interest ) is reduced from 25 percent to 10 percent and the Trinidad and Tobago withholding tax on interest is reduced from 30 percent to 15 percent where the recipient is a financial institution 34.
... recipient has a 10 percent ownership interest ) is reduced from 25 percent to 10 percent and the Trinidad and Tobago withholding tax on interest is reduced from 30 percent to 15 percent where the recipient is a financial institution 34.
Page 35
... recipient is a financial institution not having a permanent establishment in Trinidad and Tobago . Still one more point of difference between these three income tax treaties and prior treaties is that all three of the treaties provide ...
... recipient is a financial institution not having a permanent establishment in Trinidad and Tobago . Still one more point of difference between these three income tax treaties and prior treaties is that all three of the treaties provide ...
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Common terms and phrases
activities Aleutian allowed Ambassador Yost Amchitka Island Amchitka tests American amount apply Atomic Energy Commission Belgian Belgium business profits CHAIRMAN COHEN commercial profits Committee competent authorities continental shelf death taxes decedent derived dividends domicile double taxation earthquake effectively connected estate tax exempt from tax existing convention Finland Finnish foreign tax credit GILLER Government income tax treaties industrial or commercial interest Internal Revenue Code investment LARSON Latin America located megaton ment MILROW Netherlands Nevada Test Site nonresident nuclear explosions OECD Model Convention paid percent permanent establishment personal services Pitzer problem proposed convention provides purposes question radioactivity real property recipient resident respect royalties Secretary seismic Senator AIKEN Senator CHURCH Senator GRAVEL Senator SYMINGTON source country source rule statement tax imposed taxable tion Tobago corporation triggered Trinidad and Tobago tsunami U.S. income tax U.S. tax underground nuclear tests underground tests United Nations 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.