By Franz Martin Joseph
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Additional 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.
A taxpayer who proves that the actions of the taxing authorities of a treaty country have resulted or will result in double taxation with respect to any of the taxes covered by the respective conventions, is given the right to lodge a claim with the state of nationality or organization. 89. 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.
S. tax on such British or Irish royalties, are under the treaties exempt from British or Irish taxes thereon. If a permanent establishment exists, the appropriate foreign taxes still cannot be credited since the treaty credit sections refer only to taxes appropriate to dividends. 17. Biddle v. Conlln'r, 302 l'S 573 (1938). IS" Art. XIII(I). ,>1 Art. 528. 18. See prior discussion of concept of corporate residence under British and Irish income tax laws. 528. The Irish convention enlarges the proportion of the credit for Irish taxes allowable under IRC § 131, in certain cases, by providing that income derived from United Kingdom sources hy un individual resident of Ireland shall be deemed to be income from Irish sources provided it is not subject to United Kingdom income tax.