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 |
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Page 5
... involved is located . Real property includes leases of such property , unless such leases are of eighteen years ' duration or less , but excludes mortgages and other liens on such property as security . The question whether any other ...
... involved is located . Real property includes leases of such property , unless such leases are of eighteen years ' duration or less , but excludes mortgages and other liens on such property as security . The question whether any other ...
Page 13
... involved . Mr. KING . The convention is divided into four titles or sections . The first deals with taxes on estates and inheritances . At the time of our previous income tax convention with France , negotiated in the spring of 1939 ...
... involved . Mr. KING . The convention is divided into four titles or sections . The first deals with taxes on estates and inheritances . At the time of our previous income tax convention with France , negotiated in the spring of 1939 ...
Page 16
... Would it be a fair statement that the total amount involved in dollars and cents from the whole picture is relatively small compared with the total amount of either our inheritance - 16 CONVENTION WITH FRANCE ON DOUBLE TAXATION.
... Would it be a fair statement that the total amount involved in dollars and cents from the whole picture is relatively small compared with the total amount of either our inheritance - 16 CONVENTION WITH FRANCE ON DOUBLE TAXATION.
Page 17
... involved . It deals with the American business that has a branch or permanent establishment in the other country and the intercorporate relationship as between the parent corporation here and the subsidiary corporation abroad . Then we ...
... involved . It deals with the American business that has a branch or permanent establishment in the other country and the intercorporate relationship as between the parent corporation here and the subsidiary corporation abroad . Then we ...
Page 49
... involved and should be clarified . Article 6 , subdivision 2 , provides as follows : " 1. All demands for reduction or reimbursement of tax based upon the pro- visions of the present title should be presented within a period of 5 years ...
... involved and should be clarified . Article 6 , subdivision 2 , provides as follows : " 1. All demands for reduction or reimbursement of tax based upon the pro- visions of the present title should be presented within a period of 5 years ...
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.