Book/Printed Material Taxation of capital gains realized by a non-resident individual or a foreign corporation from the sale of shares in a domestic corporation in several foreign countries
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Image 1 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... TAXATION OF CAPITAL GAINS REALIZED BY A NONRESIDENT INDIVIDUAL OR A FOREIGN CORPORATION FROM THE SALE OF SHARES IN A DOMESTIC CORPORATION IN SEVERAL FOREIGN COUNTRIES Edith Palmer Senior Legal Specialist European...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 2 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... CONTENTS SUMMARY 3 Edith Palmer CHART 5 Edith Palmer ARGENTINA 6 Rubens Medina and Glenn L Reitze BELGIUM 7 George E Glos CANADA 9 Stephen F Clarke FRANCE 12 M Tahar Ahmedouamar...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 3 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... TAXATION OF CAPITAL GAINS REALIZED BY A NONRESIDENT INDIVIDUAL OR A FOREIGN CORPORATION FROM THE SALE OF SHARES IN A DOMESTIC CORPORATION IN SEVERAL FOREIGN COUNTRIES SUMMARY This report surveys the laws...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 4 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 2 common of which is the ownership of a substantial participation in a domestic corporation as expressed in a percentage of the equity owned most commonly 25 over a certain period prior...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 5 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... TAXATION OF NONRESIDENT INDIVIDUALS AND FOREIGN CORPORATIONS ON CAPITAL GAINS FROM SHARES IN DOMESTIC CORPORATIONS Nonresident individuals Foreign corporations Country All gains Some gains No gains All gains Some gains No gains...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 6 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... Nonresident individuals Foreien corporations Country Taiwan UK All gains Some gains Prepared by Edith Palmer Senior Legal Specialist European Law Division Law Library of Congress April 19 1990 No gains X X...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 7 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 5 ARGENTINA For nonresident individuals the principal Argentine tax imposed on gains from the sale of shares in Argentine corporations is the Tax on Occasional Income The rate is 15 percent of...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 8 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 6 In addition to the Tax on Occasional Income applicable to nonresident individuals or the Income Tax applicable to corporations sales of shares of stock or other securities in Argentina are subject...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 9 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 7 BELGIUM A nonresident corporation does not pay any capital gains tax on the sale of substantial shareholdings in Belgian corporations The same rule applies to nonresident individuals2 Article 13 of the...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 10 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 8 partners or managers in a resident corporation or do not reside in Belgium for at least 183 days per calendar year Prepared by George E Glos Assistant Chief European Law Division...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 11 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 9 CANADA Section 115 of Canadas Income Tax Act imposes a tax on the taxable capital gains earned by nonresidents on the disposition of taxable Canadian property Taxable Canadian property includes 1...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 12 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 10 The tax created by 115 of Canadas Income Tax Act can be avoided by a party who is able to claim the benefit of a provision similar to Article XIII1 of...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 13 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 11 written by a seller that states that he or she is a Canadian resident will normally relieve the purchaser of any liability under 116 On the other hand a statement that...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 14 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 12 FRANCE Individuals or corporations which are not domiciled in France are as a general rule taxed only on income derived from French sources and income allowed by a treaty with France...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 15 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 13 former State from stamp or like tax otherwise arising with respect to such transaction There is no definition of a foreign corporation in the French Tax Code but according to article...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 16 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 14 FEDERAL REPUBLIC OF GERMANY I Nonresident Individuals The Federal Republic of Germany imposes a capital gains tax for the sale of shares in a German corporation on nonresident individuals only under...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 17 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 15 The revenue office may collect the income tax on receipts subject to limited taxation which are not otherwise subject to withholding by the withholding method if this is advisable to secure...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 18 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 16 The domestic income which is thus subject to taxation is enumerated in section 49 paragraph 1 of the Income Tax Law 41 Included in this enumeration are substantial shareholder gains which...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 19 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 17 of domestic source income and by excluding German taxation rules if their application to the foreign taxpayer would avoid tax liability Consequently substantial shareholder gains from the sale of German corporate...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 20 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 18 INDONESIA The Income Tax Law of 1984 makes no provision for a separate capital gains tax Gains from the sale of shares in corporations are treated as normal income and are...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 21 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 19 mine or natural resource site or a fishery The definition of permanent establishment also covers the furnishing of a service in any form by an employee or other individual an employee...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 22 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 20 ITALY In Italy taxation is imposed on any income whether in money or in kind derived from any source such as capital employment independent work business and real property Specific provisions...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 23 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 21 For the purpose of income tax law companies and other entities that for the major part of the tax year have their legal or administrative headquarters or the principal purpose of...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 24 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 22 JAPAN Under the old Japanese tax law capital gains from the sale of securities by individuals were generally excluded from income tax subject to numerous exceptions However as a result of...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 25 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 23 his payment known as the information return to the tax office by the end of January following the year in which the transactions occurred art 225 The individual taxpayer is required...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 26 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 24 3 Income derived from the sale of shares of a corporation by a nonresident shareholder and other shareholders specifically related to him spouse relatives employees etc when these shareholders owned 25...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 27 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 25 It should be noted that capital gains from the sale of shares of a Japanese corporation which would otherwise be taxable for a nonresident individual are exempt from tax under article...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 28 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 26 THE NETHERLANDS Nonresident corporations that are both managed and incorporated outside the Netherlands are liable to Dutch corporate income tax in the normal manner and at normal rates on certain specific...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 29 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 27 interest in a company exists if an individual at any time during five years preceding the disposal held either directly or indirectly and either independently or jointly with close relatives at...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 30 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 28 SPAIN Structure of Capital Gains Taxation Capital gains including those realized from the sale of shares in domestic corporations are included as taxable income under the income tax laws both for...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 31 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 29 those derived from the sale of corporate shares are presently taxed at 35 percent while income from other sources including dividends is subject to a flat rate of 20 percent Income...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 32 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 30 are normally exempt from this tax as well as from the valueadded taxs charged on sales and services by businesses there are two circumstances under which the transfer tax will be...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 33 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 31 SWEDEN The Swedish taxation system is based on residency and not on nationality Hence a foreign resident is taxed on the same basis as any other Swedish national who has an...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 34 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 32 except in the event that the shares themselves are considered inventory of a business carried on by a nonresident in Sweden Prepared by Fariborz Nozari Senior Legal Specialist European Law Division...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 35 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 33 SWITZERLAND Switzerland is a Confederation of 26 cantons Taxes are therefore levied on the federal the cantonal and the municipal levels Swiss federal company law is contained in titles 2429 of...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 36 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 34 REPUBLIC OF CHINA TAIWAN A capital gains tax had been reinstated in Taiwan in September 1988 after more than a decade of suspension but an amendment to the Income Tax Law...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 37 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 35 Unless otherwise provided in this Law in the case of an individual who is a nonresident in the Republic of China but who has derived income from sources in the Republic...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990
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Image 38 of Taxation of capital gains realized by a non-resident individual or a foreign corporation ... 36 determined by the law under which they are incorporated art 2 1129 The taxation of profit seeking enterprises is set forth in article 3 of the Income Tax Law According to...- Contributor: Palmer, Edith - Law Library of Congress (U.S.)
- Date: 1990