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
... windfall to the British licensee , and not to the American company . Now , the Finance Committee has not acted upon H. R. 4952 this year . However , the Finance Committee did report favorably , in 1956 , H. R. 7643 , a bill ...
... windfall to the British licensee , and not to the American company . Now , the Finance Committee has not acted upon H. R. 4952 this year . However , the Finance Committee did report favorably , in 1956 , H. R. 7643 , a bill ...
Page 6
... windfall by being relieved of the British tax under this conven- tion . And the American corporation does not get any relief , because under its contract it still only gets the net royalty . So that it looks like a clear discrimination ...
... windfall by being relieved of the British tax under this conven- tion . And the American corporation does not get any relief , because under its contract it still only gets the net royalty . So that it looks like a clear discrimination ...
Page 7
... 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 royalty a larger figure than ...
... 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 royalty a larger figure than ...
Page 13
... windfall gain ” to some American licensors , and ( 2 ) it places United States taxpayers without United Kingdom branches in a worse position than those who have United Kingdom branches . As to the first point , " windfall gains " arise ...
... windfall gain ” to some American licensors , and ( 2 ) it places United States taxpayers without United Kingdom branches in a worse position than those who have United Kingdom branches . As to the first point , " windfall gains " arise ...
Page 14
... windfall gain " argument , it should be observed that insofar as the supple- mentary protocol adopts the tax credit approach contained in H. R. 4952 it im- plicitly rejects the validity of this argument . Conclusion This supplementary ...
... windfall gain " argument , it should be observed that insofar as the supple- mentary protocol adopts the tax credit approach contained in H. R. 4952 it im- plicitly rejects the validity of this argument . Conclusion This supplementary ...
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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...