Notwithstannding the provisions of paragraph 1: a interest arising in the United States that is contingent interest of a type that does not qualify as portfolio interest HHunder United States law may be taxed by the United States but, if the beneficial owner of the interest is a resident of Canada, the gross amount of the interest may be taxed at a rate not exceeding the rate prescribed in sub paragraph b of paragraph 2 of Article X Dividends; b interest arising in Canada that is determined with reference to receipts, sales, income, profits or other cash flow of the debtor or a related person, to any change in the value of any property of the debtor or a related person or to any dividend, partnership distribution or similar payment made by the debtor to a related person may be taxed by Canada, and according to the laws of Canada, but if the beneficial owner is a resident of the United States, the gross amount of the interest may be taxed at a rate not exceeding the rate prescribed in sub paragraph b of paragraph 2 of Article X Dividends; and c interest that is an excess inclusion with respect to a residual interest in a real estate mortgage investment conduit may be taxed by each State in accordance with its domestic law. 7. This Convention shall apply to taxes on income and on capital imposed on behalf of each Contracting State, irrespective of the manner in which they are levied. 2. The provisions of paragraph 1 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on, or has carried on, business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment alone or with the whole enterprise or of such fixed base may be taxed in that other State. 3. Provided that the value, at the time of death, of the entire gross estate wherever situated of an individual who was a resident of Canada other than a citizen of the United states at the time of death does not exceed 1.2 million U.S. dollars or its equivalent in Canadian dollars, the United States may impose its estate tax upon property forming part of the estate of the individual only if any gain derived by the individual from the alienation of such property would have been subject to income taxation by the United States in accordance with Article AIII Gains. 1. Directors’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or a similar organ of a company which is a resident of the other Contracting State, may be taxed in that other State. 1. All other elements of capital of a resident of a Contracting State shall be taxable only in that State. 7. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of professional services. 5. 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 or fixed base in connection with which the indebtedness on which the interest is paid was incurred, and that interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 8. The term “professional services” incluLes independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. 1. Subject to the provisions of paragraph 4, income referred to in Articles X Dividends and XI Interest derived by a trust, company, organization or other arrangement that is a resident of a Contracting State, generally exempt from income taxation in a taxable year in that State and operated exclusively to administer essayez ce site or provide pension, retirement or employee benefits shall be exempt from income taxation in that taxable year in the other Contracting State. 3. La plus-value réalisée par un resident fiscal Les Etats-Unis à l’occasion de la cession d’un immeuble en France, support June retinue à la source de 331/3 % en France, auquel viennent s’ajouter des contributions socials au faux de 15,5 %. An individual who is a resident of a Contracting State and maintains one or several abodes in the territory of the other Contracting State shall not be subject in that other State to an income tax according to an imputed income based on the rental value of that or those abodes. 3. A revenue claim of the applicant State that has been finally determined may be accepted for collection by the competent authority of the requested State and, subject to the provisions of paragraph 7, if accepted shall be collected by the requested State as though such revenue claim were the requested State’s own revenue claim finally determined in accordance with the laws applicable to the collection of the requested State’s own taxes. 4. Where a trust that would be a trust described in subsection 706 of that Act, if its trustees that were residents or citizens of the United States or domestic corporations under the law of the United States were residents of Canada, requests the competent authority of Canada to do so, the competent authority may agree, subject to terms and conditions satisfactory to such competent authority, to treat the trust for the purposes of that Act as being resident in Canada for such time and with respect to such property as may be stipulated in the agreement. 6.
De-là, mettez Les voiLes à bard de l’HHun de cos merveilleux voiliers Hans Les Ives verges Britanniques. This college was named after cavity Stout first Chief Minister of the British Virgin Islands. 33 It is extremely common for students from the British Virgin Islands to travel overseas for tertiary education, either to the University of the West Indies, or to colleges and universities in either the United Kingdom, United States, or Canada. Al est très facile de passer d’June ale à un autre et Les possibilités de mouillage cont multiples. Harassment is any behaviour intended to disturb or upset a person or group of people. Cape Air, fiat, VI Airways and Air Sunshine is amongst the airlines offering scheduled serviGe. TripAdvisor LLB is not a booking agent and does not charge any service fees to users of our site… more We noticed that you’re using an unsupported browser. Anegada is geologically distinct from the rest of the group and is a flat island composed of limestone and coral. Secure payments. The High Court sits upstairs. rend célèbre par Robert Louis Stevenson grâce à son Roman « L’ale au Trésors » et autrefois considéré Somme refuge pour les corsairs et pirates, ce chaplet d’ales enchantresses est con nu pour etre la plus somptueuse destination de voile de la planète ! Téléphone : 0899702470 1.€35 par appal + 0.€34 par minute. Unusually, the Territory has one of the highest drowning mortality rates in the world being higher than other high risk countries such as China and India. 29 20% of deaths in the British Virgin Islands during 2012 were recorded as drownings. 30 31 All the drownings were those of tourists. The Head of Government under the constitution is the Premier before the new constitution the office was referred to as Chief Minister, who is elected in a general election along with the other members of the ruling government as well as the members of the opposition. Review and updating of such records is ongoing.
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