Income and Estate Tax Conventions |
Common terms and phrases
50 percent ALBEN W American actor American Bar American Bar Association apply April 16 article III article VIII article XI Britain and Northern British actor British corporation British tax capital gains CARROLL Contracting Party convention with Canada DALES decedent dividends domiciled double taxation effect engaged in trade England enterprise estate tax exchange exempt from United fiscal evasion foreign corporations Foreign Relations Government income from sources income tax income-tax convention interest Internal Revenue Code McCALMAN motion-picture negotiations nonresident aliens Northern Ireland paragraph permanent establishment present Convention principle profits property situated provisions public entertainers reciprocal resident respect to taxes Revenue Act royalties Screen Actors Guild Senator LA FOLLETTE Senator LUCAS Senator WHITE shareholder STAM subcommittee subject to United surtax tax convention tax imposed tax paid taxable taxes on income territory tion trade or business transactions treaty United Kingdom corporation United Kingdom tax United States corporation United States tax vention
Popular passages
Page 12 - Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information as aforesaid shall be exchanged which would disclose any trade, business, industrial or professional secret or trade process.
Page 10 - States tax. (3) The provisions of this Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by either of the Contracting Parties for purposes of profit.
Page 6 - Article 1. (1) The taxes which are the subject of the present Convention are : (a) In the United States of America : The Federal income taxes, including surtaxes and excess profits taxes (hereinafter referred to as United States tax).
Page 74 - An alien actually present in the United States who is not a mere transient or sojourner is a resident of the United States for purposes of the Income tax. Whether he is a transient or not is determined by his intentions with regard to the length and nature of his stay.
Page 12 - The nationals of one of the Contracting Parties shall not, while resident in. the territory of the other Contracting Party, be subjected therein to other or more burdensome taxes than are the nationals of such other Contracting Party resident in its territory. (2) The term "nationals...
Page 45 - permanent establishment," when used with respect to an enterprise of one of the contracting States, means a branch, factory, mine, oil well, plantation, workshop, warehouse, installation, or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of...
Page 13 - IN WITNESS WHEREOF the above-mentioned Plenipotentiaries have signed the present Convention and have affixed thereto their seals. Done at Washington, in duplicate, on the 16th day of April, 1945.
Page 7 - permanent establishment" when used with respect to are enterprise of one of the Contracting Parties means a branch, management, factory or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of such enterprise or has a stock of merchandise from which he regularly fills orders on its behalf.
Page 11 - Dividends and interest paid on or after the first day of January 1945 by a United Kingdom corporation shall be exempt from United States tax except where the recipient is a citizen of or a resident of the United States or a United States corporation.
Page 22 - ... has been extended by the United States or the United Kingdom. (5) The provisions of the preceding paragraphs of this article shall apply to the Channel Islands and the Isle of Man as if they were colonies of the United Kingdom. ARTICLE XXIII.