Explanation of Proposed Protocol to the Income Tax Treaty Between the United States and Canada: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on May 25, 1995
U.S. Government Printing Office, 1995 - Double taxation - 45 pages
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active business test anti-treaty-shopping apply assets Canadian gains Canadian income tax Canadian resident Canadian tax Committee may wish death tax imposed decedent decedent’s deﬁnition derivative beneﬁts dividends double taxation estate tax imposed exempt existing treaty ﬁnancing ﬁrst spouse foreign tax credit gains at death gambling losses gambling winnings GATS gift tax impose an estate imposed at death Income Tax Act income tax treaties inheritance tax limitation on beneﬁts marital deduction model treaty modiﬁed Netherlands OECD ownership payments percent posed protocol Private letter rulings proposed treaty QDOT qualiﬁed qualifying person rata uniﬁed credit requirement resi resident of Canada respect revenue claim royalties second spouse source rule speciﬁc spousal trust surviving spouse TAMRA taxpayer Technical Explanation trade or business treaty beneﬁts treaty countries treaty provisions U.S. citizen U.S. estate tax U.S. income tax U.S. internal law U.S. model U.S. person U.S. resident U.S. source U.S. treaties United withholding tax