Explanation of proposed income tax treaty between the United States and Japan: scheduled for a hearing before the Committee on Foreign Relations, United States Senate, on February 25, 2004
U.S. G.P.O., 2004 - Double taxation - 120 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 aircraft in international amount apply bareboat business ac business profits competent authority coun country of residence dividends dividends paid double taxation earnings effectively connected employees enterprise fixed base foreign corporation foreign tax credit host country immovable property income derived income or profits income tax treaties internal law international traffic ments nonresident alien OECD model operation of ships paragraph payments pension performance permanent estab permanent establishment posed treaty proposed protocol proposed treaty contains Proposed treaty limitations proposed treaty provides REIT rental of ships resi resident of Sri respect royalties saving clause ships in international similar source country tax source-country taxation Sri Lanka Sri Lankan tax subject to U.S. taxable Technical Explanation term tion trade or business trea treaty benefits treaty country U.S. citizen U.S. corporation U.S. income tax U.S. law U.S. model U.S. person U.S. resident U.S. tax treaties U.S. trade U.S. treaty U.S.-source income