Bilateral Tax Treaties and Protocol: Estonia, Latvia, Venezuela, Denmark, Lithuania, Slovenia, Italy, and Germany: Hearing Before the Committee on Foreign Relations, U.S. Senate

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DIANE Publishing, Jan 1, 1999 - Business & Economics - 101 pages
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Hearing to consider bilateral income tax treaties between the U.S. and Estonia, Latvia, Lithuania, Venezuela, Denmark, Italy, and Slovenia as well as an estate tax protocol with Germany. Witnesses: Byron L. Dorgan, Senator from North Dakota; Fred F. Murray, v.p. for tax policy, National Foreign Trade Council, Wash., D.C.; Lindy L. Paull, chief of staff, Joint Committee on Taxation, U.S. Congress; Robert A. Underwood, U.S. Delegate from Guam; and Philip R. West, International Tax Counsel, U.S. Dept. of the Treasury. Website addresses for explanation of treaties.
 

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Page 84 - ... for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films and films or tapes for radio or television broad-casting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
Page 19 - The treaty contains the standard provision (the "saving clause") contained in US tax treaties that each country retains the right to tax its citizens and residents as if the treaty had not come into effect...
Page 57 - ... income tax treaties is derived from sixty years of evolution, starting with the model income tax treaty drafted by the League of Nations in 1927, culminating in its "London Model...
Page 14 - In such cases, designated tax authorities of the two governments — known as the "competent authorities" in tax treaty parlance — are to consult and reach an agreement under which the taxpayer's income is allocated between the two taxing jurisdictions on a consistent basis, thereby preventing the double taxation that might otherwise result. The US competent authority under our tax treaties is the Secretary of the Treasury.
Page 59 - Advance Pricing Agreements" or "APAs," through which tax authorities of the United States and other countries have been able to avoid costly and unproductive proceedings over appropriate transfer prices for the trade in goods and services between related entities. APAs, which are agreements jointly entered into between one or more countries and particular taxpayers, have become common and increasingly popular procedures for countries and taxpayers to settle their transfer pricing issues in advance...
Page 28 - Convention shall cease to have effect (a) in respect of taxes withheld at source, for amounts paid or credited on or after the first day of January next following the expiration of the 6 months...
Page 28 - States tax for the taxable years beginning on or after the first day of January next following the date on which such notice is given.
Page 14 - In addition to reducing potential double taxation, treaties also reduce "excessive" taxation by reducing withholding taxes that are imposed at source. Under US domestic law. payments to non-US persons of dividends and royalties as well as certain payments of interest are subject to withholding tax equal to 30 percent of the gross amount paid. Most of our trading partners impose similar levels of withholding tax on these types of income. This tax is imposed on a gross, rather than net, amount. Because...
Page 61 - Congressional staffs concerning treaty issues and negotiations and the interaction between treaties and developing tax legislation. We encourage all participants in such consultations to give them a high priority. We also respectfully encourage this Committee to schedule...
Page 23 - Convention shall cease to be effective for the taxable years beginning on or after the first day of January of the calendar year next following that in which such notice is given. (b) Meaning of terms. As used in this part, any term defined in the convention shall have the meaning...

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