Explanation of proposed income tax treaty between the United States and the Republic of Slovenia: scheduled for a hearing before the Committee on Foreign Relations, United States Senate, on October 13, 1999
U.S. G.P.O., 1999 - Business & Economics - 54 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 amount apply Article 14 article Article attributable beneficial owner business profits capital gains competent authority country of residence creation or assignment deduction dividends article dividends paid double taxation enterprise establishment or fixed fixed base foreign corporation foreign tax credit host country includes income tax treaties independent personal services Internal taxation rules international traffic main purpose tests ment nonresident alien OECD model payments payor pension percent permanent establishment proposed treaty contains Proposed treaty limitations proposed treaty provides qualified governmental entity REIT REMIC resi residents of Slovenia respect royalties saving clause ships or aircraft Slovenian resident Slovenian tax source country source-country tax subject to tax subject to U.S. taxable taxation rules United Technical Explanation tion trade or business treaty benefits treaty country treaty's U.S. and OECD 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. treaties U.S.-source income