TaxTMI 
TaxTMI 
General Definitions
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....ntracting State; the terms also include an enterprise carried on by a resident of a Contracting State through an entity that is treated as fiscally transparent in that Contracting State; (d) the term "enterprise" applies to the carrying on of any business; (e) the term "business" includes the performance of professional services and of other activities of an independent character; (f) the term "international traffic" means any transport by a ship or aircraft, except when such transport is solely between places in a Contracting State; (g) the term "competent authority" means: (i) in __________:----------; and (ii) in the United States: the Secretary of the Treasury or his delegate; (h) the term "__________:"--------- means ; ....
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....es Covered) that meets all of the following conditions: (i) results in one or more of the following: (A) a preferential rate of taxation for interest, royalties, guarantee fees or any combination thereof, as compared to income from sales of goods or services; (B) a permanent reduction in the tax base with respect to interest, royalties, guarantee fees or any combination thereof, without a comparable reduction for income from sales of goods or services, by allowing: (1) an exclusion from gross receipts; (2) a deduction without regard to any corresponding payment or obligation to make a payment; (3) a deduction for dividends paid or accrued; or (4) taxation that is inconsistent with the principles of Article 7 (Business Profits)....
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....n of which achieves a single level of taxation either in the hands of the person or the person's shareholders (with at most one year of deferral) and that hold predominantly real estate assets; and (v) after consultation with the first-mentioned Contracting State, has been identified by the other Contracting State through diplomatic channels to the first- mentioned Contracting State as satisfying clauses (i) through (iv) of this subparagraph. No statute, regulation or administrative practice shall be treated as a special tax regime until 30 days after the date when the other Contracting State issues a written public notification identifying the regime as satisfying clauses (i) through (v) of this subparagraph; and (m) two persons shal....