Explanation of proposed income tax treaty and proposed protocol between the United States and the Swiss Confederation: scheduled for a hearing before the [Committee on Foreign Relations, United States Senate], on October 7, 1997
U.S. G.P.O., Jan 1, 1997 - Business & Economics - 66 pages
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OVERVIEW OF U S TAXATION OF INTERNATIONAL TRADE AND INVESTMENT AND U S TAX TREATIES
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30-percent withholding tax activities amount attributable business profits capital gains Code competent authority coun country of residence deduction derivative benefits dividends paid double taxation effectively connected enterprise entitled to treaty establishment or fixed European Economic Area excise tax fixed base foreign corporation foreign tax credit income derived income tax treaties independent personal services international traffic Memorandum of Understanding ment NAFTA OECD model payments pension percent permanent establishment posed treaty present treaty proposed protocol proposed treaty contains proposed treaty provides REIT dividends REMIC requirements resi residence country respect royalties rule applies saving clause shareholders ships or aircraft source country tax special rule specified subject to U.S. Swiss resident Swiss tax tax fraud taxable third-country tion trade or business treaty benefits treaty country U.S. citizen U.S. corporation U.S. income tax U.S. model U.S. person U.S. real property U.S. resident U.S. tax treaties U.S. trade U.S. treaty U.S.-source income United