Explanation of Proposed Protocol to the Income Tax Treaty Between the United States and the Kingdom of the Netherlands in Respect of the Netherlands Antilles: To be Considered by the Committee on Foreign Relations, United States Senate
U.S. Government Printing Office, 1996 - Double taxation - 10 pages
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1948 Convention 30-percent withholding tax Act rule amends Article VIII Article VIII Interest Committee on Taxation considered U.S.-source income continued exemption controlled foreign corporation debt instruments issued double taxation effectively connected income enter into force erlands Eurobonds exemption from U.S. foreign cor foreign tax credit foreign-source income income earned Income Tax Treaty income taxes paid individual or foreign interest paid Internal Revenue Service Joint Committee June 22 lands Antilles Neth Netherlands Antilles subsidiary nonresident alien individual objectives of U.S. obligations issued October 15 OVERVIEW OF U.S. parent or affiliate permanent establishment poration portfolio debt obligations pursuant related controlled foreign source country specified spect subject to U.S. tax avoidance tax for interest taxes U.S. citizens Technical Explanation further termination tion trade or business Treaties generally provide treaty partner U.S. 30-percent withholding U.S. companies U.S. corporation U.S. parent U.S. person U.S. tax law U.S. tax treaties U.S. trade U.S.-source interest