Protocol

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....ica and the Government of__________ for the Avoidance of Double Taxation and the Prevention of Tax Evasion with respect to Taxes on Income (the "Convention"), the two Governments have agreed to the following provisions. 1. With reference to subparagraph (k) of paragraph 1 of Article 3 (General Definitions) of the Convention: (a) In the case of the United States, the term "pension fund"....

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....ue Ruling 81- 100, as amended by Revenue Ruling 2014-24 and Revenue Ruling 2011-1, qualifies as a pension fund only if it is operated exclusively or almost exclusively to earn income for the benefit of pension funds that are themselves entitled to benefits under the Convention as a resident of the United States. (b) In the case of__________, the term "pension fund" includes the following:....