Explanation of Proposed Income Tax Treaty Between the United States and the Republic of Austria: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 7, 1997
U.S. Government Printing Office, Jan 1, 1997 - Double taxation - 69 pages
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EXPLANATION OF PROPOSED TAX TREATY AND MEMORAN
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alternative minimum tax attributable Austrian company Austrian resident branch profits tax business profits capital gains Code competent authority coun country of residence dividends paid double taxation effectively connected enterprise entity establishment or fixed exchange of information exemption fixed base foreign corporation foreign tax credit income derived income tax treaties independent personal services interest investment nonresident alien OECD Commentary OECD model payments percent permanent establishment posed treaty present treaty proposed treaty contains proposed treaty provides provisions REIT dividends REMIC resi residence country resident of Austria respect royalties saving clause shareholders ships or aircraft sleeping partnership source country tax source income special rule subject to U.S. taxable third country tion trade or business treaty benefits treaty country resident U.S. and OECD U.S. citizen U.S. corporation U.S. income tax U.S. internal law U.S. model U.S. person U.S. real property U.S. resident U.S. tax treaties U.S. trade U.S. treaties U.S.-source Understanding provides United