Explanation of Proposed Income Tax Treaty Between the United States and Sweden: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on May 25, 1995
U.S. Government Printing Office, Jan 1, 1995 - Double taxation - 22 pages
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agreement anti-treaty-shopping provision apply branch proﬁts tax charitable organization Committee competent authorities contains the standard coun country Article deﬁned deﬁnition dends dividends double taxation effectively connected enterprise enters into force ﬁrst country ﬁxed base foreign corporation foreign source income foreign tax credit GATS income earned income tax treaty interest paid Internal Revenue Code international trafﬁc limitation nonresident alien individuals obtain treaty beneﬁts OECD model treaty passive income percent permanent establishment premiums paid present treaty proposed treaty provides real property REMIC resi rules Scandinavian Airlines System section 482 signiﬁcant speciﬁed Sweden Swedish insurers tax trea taxing jurisdiction third-country investors tion Trade in Services trade or business Transfer Pricing Treasury Department treaty also provides Treaty Doc treaty partners U.S. citizens U.S. corporation U.S. excise tax U.S. income tax U.S. model treaty U.S. person U.S. real U.S. residents U.S. source income U.S. tax treaties U.S. trade U.S. Treasury Department waiver withholding tax