Explanation of proposed protocol to the convention between the United States and Germany for the avoidance of double taxation with respect to taxes on estates, inheritances, and gifts: scheduled for a hearing before the Committee on Foreign Relations, United States Senate, on October 13, 1999
U.S. Government Printing Office, 1999 - Business & Economics - 7 pages
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50-percent marital exclusion ance tax treaty applicable exclusion amount Article 4 Fiscal avoidance of tax Chief of Staff Committee on Taxation computing the U.S. decedent or donor domicile is deemed domiciled in Germany Double Taxation duction estate and gift estate tax marital estates or gifts former U.S. citizen gift tax grant a 50-percent gross estate equals immovable property individual domiciled inheritance tax treaty Joint Committee law the estates limited U.S. estate long-term residents meaning of U.S. modify certain exemptions modify certain tiebreaker nical Explanation occurring and gifts posed Protocol principal purposes proposed protocol protocol would amend protocol would modify protocol would provide purposes the avoidance rata unified credit residents whose loss right to tax saving clause tax marital deduction tax under U.S. taxable estate tiebreaker rules described tocol treated as domiciled U.S. domestic law U.S. estate tax U.S. gross estate U.S. law U.S. real property United vidual worldwide gross estate