Convention with France on Double Taxation: Hearings Before a Subcommittee of the Committee on Foreign Relations, United States Senate, Eightieth Congress, First Session, on Executive A, Convention with France on Double Taxation, January 30, February 6, and April 17, 1947 |
From inside the book
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Page 5
... determined in conformity with the law in force in that territory . ( 2 ) In the case of the death of a person domiciled in the territory of one of the Contracting States , the situs of any of the following property or property rights ...
... determined in conformity with the law in force in that territory . ( 2 ) In the case of the death of a person domiciled in the territory of one of the Contracting States , the situs of any of the following property or property rights ...
Page 6
... determining the amount or rate of tax . However , the provisions of this Article shall not apply to the tax imposed by the United States in the case of a deceased citizen of the United States . ARTICLE 5 ( 1 ) The Contracting State ...
... determining the amount or rate of tax . However , the provisions of this Article shall not apply to the tax imposed by the United States in the case of a deceased citizen of the United States . ARTICLE 5 ( 1 ) The Contracting State ...
Page 9
... determined . ( 4 ) If the revenue claim has not been finally determined , the State to which application is made will take such measures of conservancy ( including measures with respect to transfer of property of non resident aliens ) ...
... determined . ( 4 ) If the revenue claim has not been finally determined , the State to which application is made will take such measures of conservancy ( including measures with respect to transfer of property of non resident aliens ) ...
Page 13
... determined under the laws of the respective countries . With France we agreed that after defining the same situs items , and in practically the same manner that we defined them with Canada and the United Kingdom , any situs points not ...
... determined under the laws of the respective countries . With France we agreed that after defining the same situs items , and in practically the same manner that we defined them with Canada and the United Kingdom , any situs points not ...
Page 14
... determining situs , the country of domicile of the decedent then gives a credit against its tax , of the tax paid in the other country , on items having a situs in the other country ; that involves two credit formulae , and they are the ...
... determining situs , the country of domicile of the decedent then gives a credit against its tax , of the tax paid in the other country , on items having a situs in the other country ; that involves two credit formulae , and they are the ...
Common terms and phrases
1939 convention address in France ALVORD American Chamber American citizens application article 13 article 9 assets automatic information avoidance of double Canada Carroll Chamber of Commerce competent authorities contracting convention with France decedent dividends domiciled in France double taxation enforcement entities estate tax evasion exchange of information exemption existing convention FERNALD fiscal Foreign Trade Council French convention French general income French Government French law French tax habitual residence income tax inheritance tax interest Internal Revenue July 25 KING League of Nations lines of nationality memorandum mutual assistance National Foreign Trade national solidarity tax negotiations nonresident aliens October 18 paragraph person present Convention property situated proposed convention regulations request resident in France respect ROBINSON royalties schedular Senator SMITH Senator WHITE sources STAM Sweden tax convention tax treaty taxable taxpayer territory tion Treasury treaty United Kingdom United States citizens United States tax vention
Popular passages
Page 91 - Convention by a Contracting State any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of the Convention. ARTICLE 4 Fiscal Domicile 1. For the purposes of this Convention, the term "resident of a Contracting State...
Page 10 - State may come to an agreement with the competent authority of the other State with a view to equitable avoidance of the double taxation In question.
Page 72 - States which have been finally determined shall be accepted for enforcement by the other contracting State and collected In that State in accordance with the laws applicable to the enforcement and collection of its own taxes.
Page 143 - The competent authorities of the contracting States shall exchange such information (being information available under the respective taxation laws of the Contracting States) as is necessary for carrying out the provisions of the present Convention...
Page 5 - Ships and aircraft shall be deemed to be situated at the place of registration or documentation of the ship or aircraft.
Page 142 - In the ordinary course or on request, may be exchanged directly between the competent authorities of the two contracting States. ARTICLE XX 1. The competent authorities of the United States of America shall forward to the competent authorities of Canada as soon as practicable after the close of each calendar year the following Information relating to such calendar year: The names and addresses of all persons whose addresses are within Canada and who derive from sources within the United States of...
Page 44 - Article be construed so as to impose upon either of the contracting States the obligation to carry out administrative measures at variance with the regulations and practice of either contracting State...
Page 130 - State, as provided in the succeeding articles of this convention, the information which its competent authorities have at their disposal or are in a position to obtain under...
Page 72 - ... (2) In the case of applications for enforcement of taxes, revenue claims of each of the contracting states which have been finally determined...
Page 9 - Convention relating to exchange of information and mutual assistance in the collection of taxes, such authorities may, by common agreement, prescribe rules concerning matters of procedure, forms of application and replies thereto, conversion of currency, disposition of amounts collected, minimum amounts subject to collection and related matters.