Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Italian Republic: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 13, 1999
U.S. Government Printing Office, 1999 - Business & Economics - 64 pages
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OVERVIEW OF U S TAXATION OF INTERNATIONAL TRADE AND INVESTMENT AND U S TAX TREATIES
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article Article beneﬁcial owner business proﬁts capital gains competent authorities coun country of residence credited educational deduction deﬁned deﬁnitions dividends paid double taxation earnings enterprise establishment or ﬁxed ﬁrst ﬁxed base foreign corporation foreign tax credit immovable property includes income from immovable income tax treaties independent personal services international traffic Italian main purpose test ment nonresident alien OECD model operation of ships payments payor pension percent permanent establishment present treaty proposed protocol provides proposed treaty contains Proposed treaty limitations proposed treaty provides qualiﬁed governmental entity real property REIT REMIC resi resident in Italy respect royalties saving clause scientiﬁc ships or aircraft source country tax speciﬁc subject to U.S. taxable taxes imposed taxes paid taxpayer Technical Explanation tion trade or business trea treaty beneﬁts treaty country U.S. citizen U.S. corporation U.S. income tax U.S. law U.S. model U.S. person U.S. resident U.S. tax treaties U.S. trade U.S.-source income withholding tax