Double Taxation Conventions: Hearing Before the Committee on Foreign Relations, United States Senate, Eighty-fifth Congress, Second Session, on Supplementary Income Tax Protocol with the United Kingdom (Ex. A, 85th Cong., 2d Sess.); Supplementary Income Tax Convention with Belgium (Ex. B, 85th Cong., 2d Sess.); and Notification of Extension of Income Tax Convention with the United Kingdom (Ex. C, 85th Cong., 2d Sess.) July 1, 1958 |
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Page 5
... taxpayers merely because they had adopted a partic- ular form of contract and did not have a permanent establishment in the United Kingdom directly associated with their royalties . For all of these reasons , the staff of the joint ...
... taxpayers merely because they had adopted a partic- ular form of contract and did not have a permanent establishment in the United Kingdom directly associated with their royalties . For all of these reasons , the staff of the joint ...
Page 11
... taxpayer is not entitled to a credit for the United Kingdom tax imposed on the royalty . Irving Air Chute Co. v . Commissioner ( 143 F. 2d 256 ( CCA - 2 , 1944 ) ) ; Cleveland Graphite Bronze Co. v . Commissioner ( 177 F. 2d 200 ( CCA ...
... taxpayer is not entitled to a credit for the United Kingdom tax imposed on the royalty . Irving Air Chute Co. v . Commissioner ( 143 F. 2d 256 ( CCA - 2 , 1944 ) ) ; Cleveland Graphite Bronze Co. v . Commissioner ( 177 F. 2d 200 ( CCA ...
Page 13
... taxpayer with a United Kingdom branch . At the present time , royalties paid to him are subject to British tax and he is denied a foreign tax credit . It seems unrealistic to assume that a British licensee would be willing to pay a ...
... taxpayer with a United Kingdom branch . At the present time , royalties paid to him are subject to British tax and he is denied a foreign tax credit . It seems unrealistic to assume that a British licensee would be willing to pay a ...
Page 14
... taxpayers merely because they had adopted a particular form of contract and did not have a permanent establishment in the United Kingdom directly associated with their royalties . For all of these reasons , the staff of the joint ...
... taxpayers merely because they had adopted a particular form of contract and did not have a permanent establishment in the United Kingdom directly associated with their royalties . For all of these reasons , the staff of the joint ...
Page 25
... tax- payers whose need for relief has not been demonstrated . Tax relief should not be given in this way . For these reasons I am constrained to withhold my approval of the bill . EXECUTIVE POSITION ON H. R. 4952 Con- Senator Mansfield ...
... tax- payers whose need for relief has not been demonstrated . Tax relief should not be given in this way . For these reasons I am constrained to withhold my approval of the bill . EXECUTIVE POSITION ON H. R. 4952 Con- Senator Mansfield ...
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Common terms and phrases
1948 convention 2d sess 50 percent 84th Congress 85th Cong American company American licensor amount approved August 19 bill Britain and Northern British company British licensee British overseas territories British tax British territories CARROLL CHAIRMAN Congo CONGRESS THE LIBRARY convention with Belgium directly associated eliminate double taxation Executive Foreign Relations foreign tax credit gross royalty income tax convention Internal Revenue Code Irving Air Chute KUST legislation LIBRARY OF CONGRESS mittee modified negotiate Northern Ireland notification overseas territories patent pending permanent establishment President proposed extension protocol on royalties respect retroactive Rhodesia Roan Antelope royalty agreement royalty issue royalty payments Ruanda-Urundi Senator CAPEHART Senator LONG Senator MARTIN Senator MORSE SMITH STAM statement supplementary protocol tax on royalties tax treaties taxes paid tion Treasury United Kingdom tax United States corporation United States licensor UNITED STATES SENATOR United States tax United States-United Kingdom veto windfall windfall gain withholding
Popular passages
Page 18 - ... territory named in such notification on and after the first day of January following the date of a written communication through diplomatic channels addressed to such Contracting State by the other Contracting State, after such action by the latter State as may be necessary in accordance with its own procedures, stating that such notification is accepted in respect of such territory.
Page 40 - States tax. For this purpose, the recipient of a dividend paid by a corporation which is a resident of the United Kingdom shall be deemed to have paid the United Kingdom income tax appropriate to such dividend if such recipient elects to include in his gross income for the purposes of United States tax the amount of such United Kingdom income tax.
Page 16 - Interest (on bonds, securities, notes, debentures, or on any other form of indebtedness) derived from sources within .the United States by a resident of the United...
Page 18 - Convention, or such provisions thereof as may be specified in the notification, shall apply to any territory named in such notification on and after the first day of January following the date of a written communication through diplomatic channels addressed to such Contracting State by the other Contracting State, after such action by the latter State as may be necessary in accordance with...
Page 51 - For the purposes of this section a domestic corporation which owns a majority of the voting stock of a foreign corporation from which it receives dividends in any taxable year shall be deemed to have paid the same proportion of any income, war-profits, or excess-profits taxes paid by such foreign corporation to any foreign country...
Page 13 - Convention shall be ratified and the instruments of ratification shall be exchanged at as soon as possible. 2. The Convention shall enter into force upon the exchange of instruments of ratification...
Page 2 - Treasury first — whatever the committee may desire. I would like to present Mr. Kust, so that you will know him, and Mr. Elkin. The CHAIRMAN. Shall we proceed now to hear the other witnesses? Are you finished, Senator? Senator MARTIN. Whatever the will of the committee is. I do not want to suggest the order of witnesses to the committee, but probably the Treasury would like to be heard first. The CHAIRMAN. Mr. Stam, the chief of staff of the Joint Committee on Internal Revenue Taxation is here,...
Page 30 - ... other amounts, and (ii) at no time during the taxable year in which such royalties or other amounts were so received had a permanent establishment within the United States or if such alien or corporation had a permanent establishment within the United States, the royalties or other like amounts are not directly associated with the business carried on through the permanent establishment. Such items are not, therefore, subject to the withholding provisions of the Internal Revenue Code. For the...
Page 17 - To the Senate of the United States: With a view to receiving the advice and consent of the Senate to ratification...
Page 18 - ... which imposes taxes substantially similar in character to those which are the subject of the present Convention.