1 403 F.2d 721 at 723. Some footnotes by court omitted; others renumbered.

2 7 TT. S. Treaties 1839; 273 U.N. Treaty Series 3.

3 Art. XI(1): “Nationals of either Party residing within the territories of the other Party, and nationals and companies of either Party engaged in trade or other gainful pursuit or_ in scientific, educational, religious or philanthropic activities within the territories of the other Party, shall not be subject to the payment of taxes, fees or charges imposed upon or applied to income, capital, transactions, activities or any other object, or to requirements with respect to the levy and collection thereof, within the territories of such other Party, more burdensome than those borne in like situations by nationals and companies of such other Party.” 403 F.2d 721 at 728 (quoted by court). Art. XI(2) extends this provision to nationals not resident in the territories of the other party; Art. XI(3) provides that taxes, etc., imposed upon nationals and companies of either party shall not be more burdensome than those imposed upon nationals, residents and companies of any third country.