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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

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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

Treaties
Type
Case Report
Information
International Law Reports , Volume 34 , 1967 , pp. 199 - 201
Copyright
© Cambridge University Press 1967

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