Explanation of Proposed Protocol to the Convention Between the United States and Germany for the Avoidance of Double Taxation with Respect to Taxes on Estates, Inheritances, and Gifts: 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 - 7 pages
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50-percent marital exclusion ance tax treaty applicable exclusion amount Article-by-Article explanation assets situated avoidance of tax beneﬁts center of vital Chief of Staff citizen domicil citizen or long-term Committee on Taxation country decedent or donor decedent was domiciled decedent’s estate decedent’s surviving Deputy Chief domicile is deemed domiciled in Germany domiciled may tax Double Taxation duction estate and gift estate tax marital existing treaty former U.S. citizen Generation-skipping transfers gift tax grant a 50-percent habitual abode immovable property individual domiciled individual’s center individual’s domicile inheritance tax treaty interspousal transfers Joint Committee limited U.S. estate modiﬁcations modify certain exemptions modify certain tiebreaker posed Protocol principal purposes pro rata uniﬁed proposed protocol protocol would modify protocol would provide purposes the avoidance rata uniﬁed credit SCHMITI surviving spouse tax marital deduction tiebreaker rules described tocol transfers between spouses treated as domiciled treaty applies U.S. domestic law U.S. estate tax U.S. law United vidual