By Franz Martin Joseph
Read or Download Fifth International Conference of the Legal Profession Monte Carlo (Monaco) July 19–24, 1954: Income Tax Treaties — A Comparison of Basic Provisions PDF
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Extra resources for Fifth International Conference of the Legal Profession Monte Carlo (Monaco) July 19–24, 1954: Income Tax Treaties — A Comparison of Basic Provisions
The reasoning of the Court was that the individual taxpayer had not paid the tax and that it constituted a liability of the British company 179. 8. the recipient of a dividend paid by a company which is a "resident" 182 of those countries is now deemed, for purposes of the tax credit, to have paid the Irish or British tax, as the case may be, appropriate to such dividend, provided he elects to include the amount of such tax in his gross income 183. To alien residents of the United States the treaty credit provisions assume greater importance.
The competent authorities of the countries in question shall then endeavor to arrive at an arrangement for the equitable avoidance of the particular double taxation 190. 131(a)·2. , •• Possibly the French citizen in the ruling quoted in note 1, supra, might have invoked this clause on the ground that an American citizen is entitled to credit for all foreign income taxes. On the other hand, the reply would presumably be that the taxpayer is not being subjected to higher "taxes". He merely receives a lower credit.
IRC § 131(a) (3). S. S. 2 ". 423 (France), confining the credit to trpaty-('01lntry citizens residing in the United States. EXPERIENCE WITH TREATIES TO AVOID DOUBLE TAXATION 181 The Treasury Department has ruled that under French income tax law United States citizens residing in France are not entitled to a credit for all foreign taxes. Accordingly, a French national residing in the United States was permitted to claim credit only for taxes paid to France but not for taxes paid to other foreign countries 187.