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 6
... amount that the American corporation is going to receive in the case of a gross royalty . However , in the case of a net royalty and I am talking now about a particular situation , because that is a case that was called to our attention ...
... amount that the American corporation is going to receive in the case of a gross royalty . However , in the case of a net royalty and I am talking now about a particular situation , because that is a case that was called to our attention ...
Page 7
... amount , and it is sort of a windfall to the British company . That is the problem we are concerned with . Senator LONG . Well , if the British corporation is excused from the tax on the royalty payment , why will not that make the net ...
... amount , and it is sort of a windfall to the British company . That is the problem we are concerned with . Senator LONG . Well , if the British corporation is excused from the tax on the royalty payment , why will not that make the net ...
Page 8
... amount that they get now . Senator LONG . Does the American company pay taxes to this Government on that income from his royalty ? Mr. STAM . Yes . Senator LONG . The American company pays taxes over here . And the British company is ...
... amount that they get now . Senator LONG . Does the American company pay taxes to this Government on that income from his royalty ? Mr. STAM . Yes . Senator LONG . The American company pays taxes over here . And the British company is ...
Page 11
... amounts paid as consideration for the use of , or for the privilege of using , copyrights , patents , designs ... amount of the royalty as income , subject to United States income tax . However , under the existing court decisions ...
... amounts paid as consideration for the use of , or for the privilege of using , copyrights , patents , designs ... amount of the royalty as income , subject to United States income tax . However , under the existing court decisions ...
Page 12
... amount by reason of the elimination of the United States tax , but rather will pay the same amount of tax that he is required to pay under present law . ( See appendix , example 2. ) Thus , the position of the holder of such a " net ...
... amount by reason of the elimination of the United States tax , but rather will pay the same amount of tax that he is required to pay under present law . ( See appendix , example 2. ) Thus , the position of the holder of such a " net ...
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Common terms and phrases
1948 convention 50 percent 84th Congress American company American licensor amount approved April 16 August 19 bill Britain and Northern British company British licensee British overseas territories British tax British territories CARROLL CHAIRMAN Congo Congress 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 January KUST legislation mittee modified negotiate Northern Ireland notification overseas territories patent pending permanent establishment present President proposed extension protocol on royalties relief Representative SIMPSON respect retroactive Rhodesia Roan Antelope royalties paid 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 tax United States taxpayer 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 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 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 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 53 - April 1, 1956, and section 21 must be applied to any taxable year which begins before and ends on or after April 1, 1956. Example (3). Assume that the law provides that a change In a certain rate of tax shall be effective only with respect to taxable years beginning on or after January 1. 1956. The effective date of change for purposes of section 21 is January 1, 1956, and section 21 must be applied to any taxable year which begins before and ends on or after January 1. 1956. (d) If a tax is repealed,...
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 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.
Page 11 - Service are based on the Internal Revenue Code of 1939 and the Internal Revenue Code of 1954...