Explanation of Proposed Income Tax Treaty Between the United States and the People's Republic of Bangladesh |
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Common terms and phrases
attributable Bangladesh tax benefits capital gains citizens and residents competent authorities contains the standard coun country may tax country of residence deductions derived by residents developing country dividends dividends paid domestic laws double taxation effectively connected income enterprise entertainer or athlete entity establishment or fixed exchange exempt from tax fixed base foreign corporation foreign person foreign source income foreign tax credit income tax treaties independent personal services individual Internal Revenue Code Internal Revenue Service international traffic limited nonresident alien passive income payments pensions percent permanent establishment proposed treaty contains proposed treaty provides purposes relief from double right to tax royalties rules saving clause services performed source country subject to tax tax income taxable taxes covered trade or business treaty also provides treaty country treaty partners U.S. citizen U.S. corporation U.S. income tax U.S. model U.S. person U.S. source income U.S. tax treaties United United States taxes withholding tax
Popular passages
Page 26 - Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State...
Page 16 - For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
Page 11 - international traffic" means any transport by a ship or aircraft operated by an enterprise which has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; (h) The term "competent authority...
Page 24 - Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment...
Page 5 - US tax, with two exceptions: (1) gains realized by a nonresident alien individual who is present in the United States for at least 183 days during the taxable year, and (2) certain gains from the disposition of interests in US real property.
Page 22 - annuity ' means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money's worth. Article 19.
Page 22 - Periodic payments for the support of a minor child made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support...
Page 10 - United States" means the United States of America, but does not include Puerto Rico, the Virgin Islands, Guam, or any other United States possession or territory; ii) when used in a geographical sense, the term "United States" means the states thereof and the District of Columbia.
Page 16 - Where a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State or b) the same persons participate directly or indirectly in the management, control or capital...
Page 9 - Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss.