Tax Convention with Switzerland: Report (to Accompany Treaty Doc. 105-8). |
Common terms and phrases
activities attributable beneficial owner business profits Committee competent authority country of residence dends derivative benefits dividends paid double taxation effectively connected enterprise entitled to treaty establishment or fixed European Economic Area European Union exchange of information excise tax exemption fixed base foreign corporation foreign tax credit imposed income derived income tax treaties independent personal services individual interest international traffic investment Memorandum of Understanding ment NAFTA nonresident alien payments pension percent permanent establishment posed treaty present treaty proposed protocol proposed treaty contains Proposed treaty limitations proposed treaty provides real estate REIT dividends REMIC respect royalties rule applies saving clause shareholders ships or aircraft source-country tax special rule subject to U.S. Swiss resident Swiss tax tax fraud taxable taxpayer third-country tion trade or business Treasury Department treaty benefits treaty country U.S. citizen U.S. income tax U.S. model U.S. person U.S. real property U.S. resident U.S. trade U.S. treaty U.S.-source income United