Explanation of Proposed Income Tax Treaty Between the United States and the Republic of Latvia: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 13, 1999
U.S. Government Printing Office, Jan 1, 1999 - Double taxation - 57 pages
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OVERVIEW OF U S TAXATION OF INTERNATIONAL TRADE AND INVESTMENT AND U S TAX TREATIES
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30-percent withholding tax activities amount attributable beneﬁcial owner business proﬁts capital gains competent authority coun country of residence deduction deﬁned deﬁnition dends dividends paid double taxation effectively connected enterprise establishment or ﬁxed ﬁrst ﬁxed base foreign corporation foreign person foreign tax credit host country immovable real includes income derived income from immovable income tax treaties independent personal services international trafﬁc investment investor items of income Latvian lats ment nonresident alien OECD model payments payor percent permanent establishment proposed treaty contains proposed treaty provides purposes real estate REIT dividends REMIC resi respect royalties satisﬁes saving clause scientiﬁc shareholders ships or aircraft similar source country tax speciﬁed stateless person subject to tax subject to U.S. taxable Technical Explanation tion trade or business treaty beneﬁts treaty’s U.S. and OECD U.S. citizens U.S. corporation U.S. income tax U.S. internal law U.S. model U.S. person U.S. real property U.S. tax treaties U.S. trade U.S.-source income