Land sales tax definition clarified for long-held land; residence state retains taxation rights under the treaty. The protocol defines land sales tax as a tax on sale proceeds of land held continuously for twelve years and clarifies that the phrase 'may be taxed in the other State' does not preclude the country of residence from taxing the income.
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Provisions expressly mentioned in the judgment/order text.
Land sales tax definition clarified for long-held land; residence state retains taxation rights under the treaty.
The protocol defines land sales tax as a tax on sale proceeds of land held continuously for twelve years and clarifies that the phrase "may be taxed in the other State" does not preclude the country of residence from taxing the income.
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