Hostname: page-component-78c5997874-fbnjt Total loading time: 0 Render date: 2024-11-09T07:52:39.724Z Has data issue: false hasContentIssue false

Samann v. Commissioner of Internal Revenue.

United States of America.  14 September 1961 ; 16 January 1963 .

Published online by Cambridge University Press:  01 January 2021

Get access

Abstract

Treaties — Special kinds of — Double taxation conventions — Income-Tax Convention between United States and Switzerland, 1951 — Meaning of “permanent establishment” provisions — Interpretation by United States Treasury Regulation — Effect of acquiescence in Regulation by Switzerland — The law of the United States of America.

Treaties — Interpretation of — Rules of — Conduct of the parties — Double Taxation Convention between United States and Switzerland, 1951 — Meaning of “permanent establishment” proviso — Interpretation by United States Treasury Regulation — Effect of acquiescence in Regulation by Switzerland — The law of the United States of America.

Keywords

Type
Case Report
Copyright
© Cambridge University Press 1967

Access options

Get access to the full version of this content by using one of the access options below. (Log in options will check for institutional or personal access. Content may require purchase if you do not have access.)