Explanation of proposed income tax treaty between the United States and Japan: scheduled for a hearing before the Committee on Foreign Relations, United States Senate, on February 25, 2004
U.S. G.P.O., 2004 - Business & Economics - 120 pages
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amount anti-conduit rules apply assets beneficial owner billion business profits competent authority contingent interest coun country of residence direct investment dividends paid domestic corporation double taxation effectively connected enterprise entity exemption FIRPTA five percent foreign corporation foreign tax credit host country imposed income derived income tax treaties international traffic item of income Japa Japanese persons Japanese tax ment nonresident alien OECD model operation of ships paragraph pension permanent establishment personal services posed treaty present treaty proposed treaty contains proposed treaty provides purposes reinsurer REIT resi resident of Japan respect royalties saving clause shares source country subject to tax subject to U.S. tax law taxable taxpayer Technical Explanation tion Tokumei Kumiai trade or business Transfer Pricing trea treaty benefits treaty country U.S. citizen U.S. corporation U.S. income tax U.S. internal law U.S. law U.S. model U.S. persons U.S. real property U.S. tax treaties U.S. trade U.S. treaty United withholding tax