14.1 Introduction to Article XIV – Independent Personal ServicesArticle XIV deals with the provision of independent services in one Contracting State by an individual who is...
12.3.2[a] Article XII(1) – Residence – Based Jurisdiction to TaxParagraph 1 of Article XII stands for the proposition that a resident of a country receiving royalty income...
12.3.1 U.S. Taxation of Outbound Royalty Payments 12.3.1[a] Definition of RoyaltiesThe Code generally defines the term “royalty” by enumerating the kinds of property...
If a taxpayer has personal relations with one country (Home) and derives income from another country (Host) it can cause a double taxation issue. The host country will most likely...