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 August 9, 1988
U.S. Government Printing Office, 1988 - Double taxation - 23 pages
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50 percent anti-treaty shopping provision base erosion beneficial owner benefits article branch profits tax business profits article Code sec Code section dend discussion of Article dividends paid double taxation effectively connected entitled establishment or fixed exemption from French existing treaty fixed base foreign corporation foreign tax credits French corporation French residents French tax income or gain income tax treaty interest Internal Revenue Code liability limitation on benefits nent establishment paid by French payor posed protocol principal purpose test proposed proto protocol would add protocol would allow protocol would amend public company test qualified resident reinsurance relief from double residents of France source country taxation source rule taxable Technical Explanation tocol trade or business treated as U.S. treaty benefits treaty country resident treaty shopping treaty to clarify treaty's U.S. citizens U.S. corporation U.S. income tax U.S. model treaty U.S. permanent establishment U.S. resident U.S. tax U.S. trade U.S. withholding tax United