...purposes and receives royalties from US sources that are not effectively connected with the conduct of a trade or business In the United States. Some of A's...applies only to the extent that the income derived by §1.894-1T such partnership is subject to tax in that State as the income of a resident, either in...

...trade or business in the United States. Article 10 of the US-X tax treaty provides that "dividends derived from sources within a Contracting state by...incorporation, or any other criterion of a similar nature . . .". The US-X treaty contains no provision regarding income paid or derived through a partnership....

...limited to 5 percent of the gross amount of the royalties in the source country. Article 4.1 of the US-X treaty provides that for purposes of the treaty, "a...residence, place of management, place of incorporation, or iay other criterion of a similar nature * * *". The US-X treaty does not include a provision relating...

...definition is, of course, exclusively for purposes of the Convention. Paragraph l provides that the term "resident of a Contracting State" means any person...incorporation, or any other criterion of a similar nature. The phrase "any other criterion of a similar nature" includes, for US purposes, an election under the...

...are the subject of the Convention. ARTICLE 4: RESIDENT 1. For purposes of this Convention, the term "resident of a Contracting State" means any person...tax therein by reason of his domicile, residence, citizenship, place of management, place of incorporation, or any other criterion of a similar nature,...

...the United States. The proposed treaty generally defines "resident of a Contracting State" to mean any person who, under the laws of that State, is liable...tax therein by reason of his domicile, residence, citizenship, place of incorporation, or any other criterion of a similar nature. However, the term...

..."resident of a Contracting State" to mean any person who, under the laws of that State, is subject to tax therein by reason of his domicile, residence,...incorporation, or any other criterion of a similar nature. However, the term "resident of a Contracting State" does not include any person who is subject to tax...

..."resident of a Contracting State" to mean any person who, under the laws of that State, is subject to tax therein by reason of his domicile, residence,...incorporation, or any other criterion of a similar nature.13 The term resident of a Contracting State" does not include, however, any person who is subject...

...laws of either the United States or Tunisia is subject to tax in that country by reason of his or her domicile, residence, place of management, place of...incorporation, or any other criterion of a similar nature. It is understood that a partnership is considered a resident of either country only to the extent that...

...Convention applies. - 8 Art ic 1 e 4 Residence ]. For the purposes of this Convention, the tern "resident o* a Contracting State" means any person who, under the...that State, is liable to tax therein by reason of his coricile, residence, place of nanagencnt, place of incorporation, or any other criterion of a sinilar...