Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States of America And the Republic of India : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-20-90

Cover Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States of America And the Republic of India : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-20-90
Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States of America And the Republic of India : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-20-90
United States. Congress. Joint Committee On Taxation
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(How- ever, even absent a specific provision, the Internal Revenue Service has taken the position that the United States retains the right to tax former citizens resident in the treaty partner (Rev. Rul. 79-152, 1979-1 C.B. 237).) Exceptions to the saving clause are provided for certain benefits conferred by the articles dealing with associated enterprises (Arti- cle 9), pensions and child support (Article 20), relief from double taxation (Article 25), nondiscrimination (Article 26), and mutual... agreement procedures (Article 27). The benefits in question are con- ferred by each country on it own citizens and residents as well as the citizens and residents of the other country. In addition, the benefits conferred by the articles dealing with the taxation of income received in respect of government service (Article 19), stu- dents and apprentices (Article 21), professors and teachers (Article 22), and diplomatic agents and consular officers (Article 29), are provided by each country to its residents who are neither citizens of, nor have immigrant status in, that country.

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