Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Italian Republic: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 13, 1999
U.S. Government Printing Office, 1999 - Double taxation - 64 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 article Article beneficial owner business profits capital gains competent authorities coun country of residence creation or assignment credited educational deduction dividends article dividends paid double taxation earnings effectively connected enterprise establishment or fixed fixed base foreign corporation foreign tax credit immovable property includes income from immovable income tax treaties international traffic Italian Italian resident main purpose tests ment nonresident alien OECD model operation of ships payments payor pension percent permanent establishment present treaty proposed protocol provides proposed treaty contains Proposed treaty limitations proposed treaty provides qualified governmental entity real property REIT REMIC resi resident of Italy respect saving clause ships or aircraft similar source country tax subject to U.S. taxable taxes paid taxpayer Technical Explanation 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.-source income withholding tax