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Your search keyword '"PROVISIONAL application of treaties"' showing total 5 results
Start Over Descriptor "PROVISIONAL application of treaties" Topic double tax agreements
5 results on '"PROVISIONAL application of treaties"'

1. The Services PE Provision of the Canada-US Income Tax Treaty.

Author

Sinclair, Los-na

Subjects
PERMANENT establishments (Taxation), PROVISIONAL application of treaties, INCOME tax, DOUBLE tax agreements, RULES, TAXPAYER compliance
Abstract

The article discusses the application of the services permanent establishment (PE) provision which was added by the fifth protocol to the Canada-U.S. income tax treaty, effective as of January 10, 2010. It says that the provision establishes two tests which are single-individual and enterprise tests. It mentions several steps to prepare businesses for the new rules including review of staff on projects, creation of systems to track employees, and development of taxpayer compliance policies.

Published
2009

2. Financing US Subsidiaries of Canadian Companies; Impact of New Developments.

Author

Stricof, Robert and Slaats, Sandra

Subjects
BUSINESS enterprises, SUBSIDIARY corporations, PROVISIONAL application of treaties, DOUBLE tax agreements, INCOME tax, FINANCE
Abstract

The article discusses the impact of new developments to financing of U.S. subsidiaries of Canadian companies. It mentions various ways to implement tax treatment of stocklending/sale and repurchase (repo) transactions. It also talks on the emergence of the financing provisions of the fifth protocol to the Canada-U.S. tax treaty on January 1, 2010 and the U.S.-Hungary negotiation of a new income tax treaty which have negative effects on certain common financing structures.

Published
2009

3. The Uneasy Case and Fate of Article 293 Second Indent EC.

Author

Hinnekens, Luc

Subjects
DOUBLE tax agreements, TREATY interpretation & construction, TREATY termination, PROVISIONAL application of treaties
Abstract

The article offers information on the Article 293 second indent European Community (EC) on double taxation. It states that the article is the deprived provision nestled in the unstructured odd collection of General and Final Provisions in the EC Treaty. It views the expression Member States as traditionally refers to the Treaty to all Member States. It cites the Treaty of Lisbon if ratified will drop the Article 293 EC from the new text.

Published
2009

4. Diet's US treaty ratification to bring new benefits.

Author

Takisaki, Akio

Subjects
TAX laws, DOUBLE tax agreements, RATIFICATION of treaties, PROVISIONAL application of treaties, INTERNATIONAL relations
Abstract

Emphasizes the need for Japan to introduce domestic tax rules to conform to the Japanese Diet's U.S. tax treaty. Requirement for U.S. residents to submit a certain application to receive benefits under the treaty; Personal information needed in the application; Addition of a transactional-net-margin method in the provision of the domestic tax law.

Published
2004

5. NEW ZEALAND PROTOCOL.

Author

Cohen, Harrison

Subjects
DOUBLE tax agreements, PROVISIONAL application of treaties, INTERNATIONAL economic relations
Abstract

The article reports on the protocol signed by the government officials of U.S. and New Zealand to amend their income tax treaty that has not been updated since 1982. Accordingly, the 2008 protocol will make an additional provision on financially transparent entities to its general scope. Moreover, it will also lessen the gross-basis rates of some cross-border income of persons granted to treaty benefits.

Published
2009

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