Capital Gains

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.... a Contracting State and movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. 2. Gains from the alienation of any property, other than those re....

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....of shares or comparable interests, such as interests in a partnership or trust, may be taxed in the other [Contracting State] if, at any time during the 365 days preceding the alienation, these shares....