TaxTMI 
TaxTMI 
Interest
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....erson with respect to the debtor may be taxed in __________, and according to the laws of __________, but if the beneficial owner is a resident of the United States, the interest may be taxed at a rate not exceeding 15 percent of the gross amount of the interest; (b) interest arising in the United States that is contingent interest of a type that does not qualify as portfolio interest under the law of the United States may be taxed by the United States, but if the beneficial owner is a resident of __________, the interest may be taxed at a rate not exceeding 15 percent of the gross amount of the interest; (c) interest arising in a Contracting State and beneficially owned by a resident of the other Contracting State that is....
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....ith respect to the domestic entity immediately prior to the date on which the acquisition of the domestic entity was completed; (e) interest arising in a Contracting State and beneficially owned by a resident of the other Contracting State that is a connected person with respect to the payor of the interest may be taxed in the first-mentioned Contracting State in accordance with domestic law if such resident benefits, at any time during the taxable year in which the interest is paid, from notional deductions with respect to amounts that the Contracting State of which the beneficial owner is resident treats as equity; (f) interest arising in a Contracting State and beneficially owned by a resident of the other Contracting S....
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....exceed the highest rate among the rates of tax to which persons described in subparagraph (e) of paragraph 7 of Article 22 (Limitation on Benefits) of this Convention (notwithstanding the requirements referred to in subparagraphs (a) and (b) of this paragraph) would have been entitled if such persons had received the interest directly. For purposes of this paragraph, a person described in clause (iii) of subparagraph (e) of paragraph 7 of Article 22 (Limitation on Benefits) shall be treated as entitled to the limitation of tax to which such person would be entitled if such person were a resident of the same Contracting State as the company receiving the interest. 4. The term "interest" as used in this Article means income from debt-claim....
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....le 6 (Income from Real Property (Immovable Property)) or paragraph 1 of Article 13 (Gains), and such interest is borne by such permanent establishment or allocable to such profits, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment is situated or from which such profits are derived. 7. The excess, if any, of the amount of interest allocable to the profits of a company resident in a Contracting State that are: (a) attributable to a permanent establishment in the other Contracting State (including gains under paragraph 3 of Article 13 (Gains)); or (b) subject to tax in the other Contracting State under Article 6 (Income from Real Property (Immovable Property)) or para....