Reciprocal airline tax exemption: aircraft registration determines eligibility for bilateral income tax exemption. Agreement implements a reciprocal exemption from income tax for international airlines by giving effect under Section 90, directing that exchanged letters modifying the avoidance-of-double-taxation arrangement be treated as domestic law so that income from the operation of qualifying aircraft is exempt. The exchange confirms the aircraft registration requirement: income exempt from U.S. tax must derive from aircraft registered in India to obtain reciprocal exemption, and India grants equivalent exemption to U.S.-registered aircraft operated by U.S. corporations and nonresident U.S. citizens.
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.
Reciprocal airline tax exemption: aircraft registration determines eligibility for bilateral income tax exemption.
Agreement implements a reciprocal exemption from income tax for international airlines by giving effect under Section 90, directing that exchanged letters modifying the avoidance-of-double-taxation arrangement be treated as domestic law so that income from the operation of qualifying aircraft is exempt. The exchange confirms the aircraft registration requirement: income exempt from U.S. tax must derive from aircraft registered in India to obtain reciprocal exemption, and India grants equivalent exemption to U.S.-registered aircraft operated by U.S. corporations and nonresident U.S. citizens.
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