Explanation of Proposed Protocol to the Income Tax Treaty Between the United States and France: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on April 26, 1984
U.S. Government Printing Office, 1984 - Double taxation - 26 pages
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alimony anti-treaty shopping Article 14 artiste or athlete assets situated benefits calendar capital gains capital taxes country may tax credit for French derived by French dividends double taxation relief exchange exempt from French exempt from tax existing treaty fixed base foreign tax credit French francs French residents French tax credit French tax exemption French taxes paid French wealth tax French-source income income of U.S. income tax treaty Independent Personal Services interest paid partnership income accruing percent permanent establishment present treaty rule proposed protocol protocol provides protocol would amend protocol would provide public entertainers remuneration residing in France retirement plan ship or aircraft situated outside France source country tax subject to French tax credit rules tax the income taxable taxation relief provisions treaty provision U.S. and French U.S. citi U.S. citizens residing U.S. foreign tax U.S. income tax U.S. model treaty U.S. real property U.S.-source income United withholding tax zens residing