in-print-bilateral-benefits-0409-en

Forexampleaninternationalairline

Info iconThis preview shows page 1. Sign up to view the full content.

View Full Document Right Arrow Icon
This is the end of the preview. Sign up to access the rest of the document.

Unformatted text preview: applied separately to each source of income that is earned from the other contracting state (Canada in the situation outlined above). Tr ade or Business The term “trade or business” is not defined in the protocol, and the technical explanation does not elaborate on its meaning. undefined terms should have the same meaning that they have under the law of the country that applies to the provision. Thus, for us tax purposes, the term “trade or business” should have the same meaning that it has in section 367(a) of the irC. in general, a trade or business should be considered to be a specific unified group of activities that constitute or could constitute an independent economic enterprise carried on for profit. Treas. reg. 1.367(a)2T(b)(2) further provides that a trade or business is ordinarily a group of activities that includes “every operation which forms a part of, or a step in, a process by which an enterprise may earn income or profit,” and ordinarily includes the collection of income and the earning...
View Full Document

This note was uploaded on 11/03/2013 for the course ACCOUNTING 346 taught by Professor William during the Fall '12 term at DeVry Chicago.

Ask a homework question - tutors are online