Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Republic of Turkey: 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 - 56 pages
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30-percent withholding tax activities Article attributable business proﬁts capital gains competent authority coun country of residence country tax deﬁned deﬁnition dends dividends paid double taxation drilling rig effectively connected enterprise entity establishment or ﬁxed exemption ﬁrst ﬁxed base ﬁxed place foreign corporation foreign persons foreign tax credit host country includes income derived income tax treaties independent personal services interest investor ment nonresident alien OECD models ofﬁce payments payor percent permanent establishment proposed treaty contains Proposed treaty limitations proposed treaty provides REIT dividends REMIC resi respect royalties saving clause shareholders shares or bonds ships and aircraft source country tax source country taxation speciﬁed subject to U.S. taxable Technical Explanation tion trade or business treaty beneﬁts treaty country treaty’s Turkish tax U.S. and OECD U.S. citizen U.S. corporation U.S. income tax U.S. internal law U.S. law U.S. model U.S. person U.S. real property U.S. tax treaties U.S. trade U.S. treaties U.S.-source income