Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Kingdom of Denmark: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 13, 1999
U.S. Government Printing Office, 1999 - Double taxation - 58 pages
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OVERVIEW OF U S TAXATION OF INTERNATIONAL TRADE AND INVESTMENT AND U S TAX TREATIES
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activities apply Article attributable base erosion test beneﬁcial owner business proﬁts carbon Tax Code competent authority coun country of residence Danish hydrocarbon tax Danish tax deductible deﬁned deﬁnition Denmark derivative beneﬁts dividends dividends paid double taxation effectively connected enterprise entity establishment or ﬁxed exemption ﬁrst ﬁxed base foreign corporation foreign tax credit Hydrocarbon Tax Act income derived income tax treaties independent personal services interest internal law nonresident alien OECD model payments pension permanent establishment posed treaty proposed protocol proposed treaty contains Proposed treaty limitations proposed treaty provides qualiﬁed real property resi revenue claim royalties satisﬁes saving clause ships or aircraft similar source country tax speciﬁc taxable nonstock corporation taxes imposed taxes paid taxpayer Technical Explanation third country tion trade or business treaty beneﬁts treaty country treaty’s U.S. citizens U.S. corporation U.S. income tax U.S. law U.S. model U.S. resident U.S. tax treaties U.S. trade U.S.-source income withholding tax