Explanation of Proposed Protocol to the Income Tax Treaty Between the United States and the Kingdom of Netherlands in Respect of the Neterlands Antilles: To be Considered by the Committee on Foreign Relations, United States Senate
U.S. Government Printing Office, Jan 1, 1996 - Double taxation - 10 pages
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1948 Convention 30-percent withholding tax amends Article VIII Antilles in order Article VIII Interest Committee on Taxation controlled foreign corporation debt instruments issued Deﬁcit Reduction Act double taxation effectively connected income enter into force erlands Eurobonds exemption from U.S. ﬁxed ﬂat foreign cor foreign tax credit foreign-source income income earned Income Tax Treaty income taxes paid individual or foreign interest paid Internal Revenue Service Joint Committee June 22 lands Antilles modiﬁcation Neth Netherlands Antilles subsidiary nonresident alien individual objectives of U.S. obligations issued October 15 OVERVIEW OF U.S. parent or affiliate permanent establishment poration portfolio debt obligations posed protocol proposed protocol amends pursuant related controlled foreign source country speciﬁed spect subject to U.S. tax avoidance Technical Explanation further tion trade or business Treasury Department’s Treaties generally provide treaty partner U.S. companies U.S. corporation U.S. parent U.S. person U.S. tax law U.S. tax rules U.S. tax treaties U.S. trade U.S.-source interest