Explanation of proposed income tax treaty between the United States and the United Kingdom: scheduled for a hearing before the Committee on Foreign Relations, United States Senate on March 5, 2003
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Overview of U S Taxation of International Trade and Investment and U S Tax Treaties
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activities allocation amount anti-conduit rule attributable business profits Code competent authority conduit arrangement coun country of residence deductible dividends dividends paid domestic law domestic tax law double taxation effectively connected enterprise equivalent beneficiaries exemption foreign corporation foreign tax credit gains host country income tax treaties individual insurance excise tax interest internal law international traffic items of income ment nonresident alien notes provide OECD model paragraph payments percent permanent establishment Petroleum Revenue Tax posed treaty present treaty proposed protocol proposed treaty contains proposed treaty provides real property Relief from Double repurchase agreement resi respect royalties saving clause similar source country taxes paid taxpayers Technical Explanation tion trade or business Transfer Pricing trea treaty benefits treaty country U.K. company U.K. Petroleum Revenue U.S. citizen U.S. domestic tax U.S. income tax U.S. law U.S. model U.S. resident U.S. tax treaties U.S. trade U.S.-source income United Kingdom withholding tax zero rate zero-rate provision