in-print-bilateral-benefits-0409-en

Duringthe2008roundtable63thecraconfirmedthatincomefort

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Unformatted text preview: ntion between the government of the united states of america and Finland for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on income and on Capital, signed at Helsinki on september 21, 1989, as amended by the protocol signed at Washington on May 31, 2006; and article 28(3) of the Convention between the united states of america and germany for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on income and Capital and to Certain Other Taxes, signed at bonn on august 29, 1989, as amended by the protocol signed at berlin on June 1, 2006. 49 supra note 17. 50 supra note 10. 108 n c anadian tax journal / revue fiscale canadienne ( 2009) vol. 5 7 , n o 1 value of (for example, a us company), and at least 50 percent of the vote and value of any disproportionate shares (in neither case including debt substitute shares) must be owned, directly or indirectly, either by qualifying persons or by persons (referred to as...
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