 | Administrative law - 1980 - 476 pages
...corporation had a permanent establishment within the United States, the royalties and 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.... | |
 | United States. Congress. Senate. Committee on Foreign Relations - Double taxation - 1958 - 64 pages
...The present treaty amendment would simply extend the exemption from British tax on royalties to am American licensor who has a permanent establishment...the existing treaty to dividend recipients. A United States licensor would be allowed to credit against his United States tax on the gross amount of the... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - Aliens - 1962 - 1532 pages
...(Riddle v. Commissioner of Internal Revenue, 302 US 573 (1938)). The existing income tax treaty between the United States and Great Britain was negotiated...the existing treaty to dividend recipients. A United States licensor would be allowed to credit against his United States tax on the gross amount of the... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - Aliens - 1962 - 1528 pages
...(Biddle v. Commissioner of Internal Revenue, 302 US 573 (1938)). The existing income tax treaty between the United States and Great Britain was negotiated...the existing treaty to dividend recipients. A United States licensor would be allowed to credit against his United States tax on the gross amount of the... | |
 | Administrative law - 1960 - 534 pages
...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.... | |
 | Administrative law - 1969 - 430 pages
...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.... | |
 | Administrative law - 1970 - 442 pages
...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.... | |
 | Administrative law - 1973 - 444 pages
...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 Re*~enue Code.... | |
 | Administrative law - 1968 - 424 pages
...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.... | |
 | United States. Internal Revenue Service - Tax administration and procedure - 1960 - 1384 pages
...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.... | |
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... 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... 