Explanation of Proposed Income Tax Treaty Between the United States and the Grand Duchy of Luxembourg: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 7, 1997
U.S. Government Printing Office, Jan 1, 1997 - Double taxation - 71 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 attributable base erosion test bourg branch proﬁts tax branch tax business proﬁts capital gains Code competent authority deﬁned deﬁnition derivative beneﬁts dividend tax dividends paid double taxation effectively connected enterprise entity establishment or ﬁxed excise tax ﬁrst ﬁxed base foreign corporation foreign tax credit income derived income tax treaties independent personal services interest Luxem Luxembourg resident Luxembourg tax ment NAFTA nonresident alien OECD model ownership permanent establishment posed treaty present treaty proposed MLAT proposed treaty contains proposed treaty provides purposes qualiﬁed resident reinsurance REIT dividends resi residence country royalties saving clause shareholders shares source country tax special rule speciﬁed subject to U.S. taxable taxpayer Technical Explanation provides third country tion trade or business trea treaty beneﬁts treaty country U.S. citizen U.S. corporation U.S. income tax U.S. internal law U.S. model U.S. person U.S. real property U.S. resident U.S. tax treaties U.S. trade U.S. treaties United withholding tax