Explanation of proposed income tax treaty between the United States and the French Republic: scheduled for a hearing before the Committee on Foreign Relations, United States Senate, on May 25, 1995
U.S. Government Printing Office, 1995 - Business & Economics - 32 pages
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agreement anti-treaty-shopping apply arbitration arm's length principle avoir fiscal branch profits tax branch tax Code Committee competent authorities coun country Article country taxation diplomatic notes dividends double taxation effectively connected entity establishment or fixed excise tax fixed base foreign corporation foreign source income foreign tax credit France GATS imposed income derived income tax treaties international traffic limited Netherlands nondiscrimination nonresident alien OECD model treaties percent permanent establishment permitted to tax posed treaty present treaty proposed treaty contains proposed treaty provides provision real property recent U.S. treaties resi residence country royalties shareholders SICAV similar source country source-country taxation special rule taxpayers Technical Explanation third country tion trade or business treaty benefits treaty country Treaty Doc U.S. and OECD U.S. citizen U.S. corporation U.S. income tax U.S. model treaty U.S. person U.S. resident U.S. source income U.S. tax treaties U.S. trade U.S. Treasury Department United Unlike the U.S. waiver withholding tax