Double Taxation Avoidance Agreement: Between India and the U. S. A.

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....rnment hereby directs that all the provisions of the said Agreement shall be given effect to in the Union of India. ANNEXURE Embassy of the United States of America, New Delhi April 12, 1989. Excellency, I have the honour to propose that the Government of the United states of America and the Government of India conclude an agreement to exempt from income tax, on a reciproal basis, income derived by residents of the other country from the international operation of ships and aircraft. The terms of the Agreement are as follows: The Government of the United States of America, in accordance with sections 872(b) and 883(a) of the Internal Revenue Code, agrees to exempt from tax gross income derived from the international operation of ships o....

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....s of ships and aircraft used in international transport, income from the rental of containers and related equipment used in international transport, and gain on the disposition of ships or aircraft, provided in each case that the income is incidental to the international operation of ships or aircraft. Gross income from the international operation of ships or aircraft also includes income derived from participation in a pool, a joint business, or an international operating agency and interest on funds connected with the international operation of ships or aircraft. The Government of the United States of America considers that this Note, together with your reply Note confirming that the Government of India agrees to these terms, constitutes....

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....the United States or residents of another country which grants a reciprocal exemption to Indian residents and corporation; or (2) the corporation's stock is primarily and regularly traded on an established securities market in the United States, or is wholly owned by a corporation whose stock is so traded and which is also organized in the United States. Gross income includes all income derived from the international operation of ships or aircraft, including income from the rental of ships or aircraft on a full (time or voyage) basis. It also includes income from the rental on a bareboat basis of ships and aircraft used in international transport, income from the rental of containers and related equipment used in international transport, ....