By Franz Martin Joseph
Read Online or Download Fifth International Conference of the Legal Profession Monte Carlo (Monaco) July 19–24, 1954: Income Tax Treaties — A Comparison of Basic Provisions PDF
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Additional info for Fifth International Conference of the Legal Profession Monte Carlo (Monaco) July 19–24, 1954: Income Tax Treaties — A Comparison of Basic Provisions
Sample text
1 Art. 528. 18. See prior discussion of concept of corporate residence under British and Irish income tax laws. 528. The Irish convention enlarges the proportion of the credit for Irish taxes allowable under IRC § 131, in certain cases, by providing that income derived from United Kingdom sources hy un individual resident of Ireland shall be deemed to be income from Irish sources provided it is not subject to United Kingdom income tax. , •• IRC § 131(a) (3). S. S. 2 ". 423 (France), confining the credit to trpaty-('01lntry citizens residing in the United States.
14; Greece, Art. XVII; Netherlands, Art. XXIV; New Zealand, Art. XVIII(I); Norway, Art. XIX; Sweden, Art. XX; Switzerland, Art. XVII(I); Union of South Africa, Art. XIII. The treaties with Ireland and the United Kingdom, while reciting the general prohibitions against imposition of more burdensome taxes, contain no provision specifying the method for claiming relief from double taxation.
17. Biddle v. Conlln'r, 302 l'S 573 (1938). IS" Art. XIII(I). ,>1 Art. 528. 18. See prior discussion of concept of corporate residence under British and Irish income tax laws. 528. The Irish convention enlarges the proportion of the credit for Irish taxes allowable under IRC § 131, in certain cases, by providing that income derived from United Kingdom sources hy un individual resident of Ireland shall be deemed to be income from Irish sources provided it is not subject to United Kingdom income tax.