A comparative analysis of the 1981 and 1996 U.S. Model Income Tax Treaties

Discusses how to determine source of income in order to tax nonresidents and whether nonresident taxpayers can avoid or evade US taxation by taking advantage of tax treaties negotiated between the US and countries with which they have no connection.

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Bibliographic Details
Published in:International tax journal 1998-10, Vol.24 (4), p.9-18
Main Author: O'Connor, Walter F
Format: Article
Language:English
Subjects:
Comparative analysis
Differences
Income tax
Income taxes
International cooperation
Permanent establishment
Personal holding companies
Provisions
Royalties
Tax court decisions
Tax courts
Tax evasion
Tax legislation
Tax policy
Tax rates
Tax treaties
Taxation
Taxation, Double
Treaties
United States
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Description
Summary:Discusses how to determine source of income in order to tax nonresidents and whether nonresident taxpayers can avoid or evade US taxation by taking advantage of tax treaties negotiated between the US and countries with which they have no connection.
ISSN:0097-7314