Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and Portugal: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on May 25, 1995
U.S. Government Printing Office, 1995 - Double taxation - 34 pages
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amount apply Code sec competent authority coun country of residence country tax dends dividends paid domestic law double taxation effectively connected enterprise entity establishment or fixed fixed base foreign corporation foreign source income foreign tax credit GATS gift and inheritance imposed income derived income tax treaties inheritance tax interest paid limited nonresident alien OECD model treaty paragraph passive income payments percent permanent establishment Portugal Portuguese companies Portuguese corporation posed treaty proposed protocol proposed treaty Article proposed treaty contains proposed treaty provides real property residence country royalties Santa Maria Island similar source country source-country taxation specific substitute gift taxing jurisdiction Technical Explanation tion trade or business Treasury Department treaty and protocol treaty country Treaty Doc treaty partner U.S. citizens U.S. corporation U.S. income tax U.S. model treaty U.S. residents U.S. source income U.S. tax treaties U.S. taxpayers U.S. trade U.S. Treasury Department U.S. treaties United withholding rate withholding tax