Taxes on income: treaty covers income taxes and gains, extending to identical future taxes with mutual notification. Article 2 provides that the Convention applies to taxes on income imposed on behalf of a Contracting State irrespective of how they are levied, includes taxes on total income and elements of income such as gains from alienation of property, specifies the existing taxes covered (including the United States' federal income taxes and certain federal taxes on investment income of foreign private foundations), and extends to identical or substantially similar taxes enacted later, with a duty of the competent authorities to notify each other of significant legislative changes.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxes on income: treaty covers income taxes and gains, extending to identical future taxes with mutual notification.
Article 2 provides that the Convention applies to taxes on income imposed on behalf of a Contracting State irrespective of how they are levied, includes taxes on total income and elements of income such as gains from alienation of property, specifies the existing taxes covered (including the United States' federal income taxes and certain federal taxes on investment income of foreign private foundations), and extends to identical or substantially similar taxes enacted later, with a duty of the competent authorities to notify each other of significant legislative changes.
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