- 60 - 1949, 1990-2 C.B. 274.21 We have considered all of the other arguments made by respondent and, to the extent we have not addressed them, find them to be without merit. Decision will be entered for petitioner. Reviewed by the Court. COHEN, CHABOT, JACOBS, GERBER, PARR, WELLS, WHALEN, BEGHE, LARO, and VASQUEZ, JJ., agree with this majority opinion. CHIECHI, J., did not participate in the consideration of this opinion. 21Art. 7(7) of the U.S.-New Zealand Convention includes a provision regarding the taxation of permanent establishments of insurance companies. This provision provides: Nothing in this Article shall prevent either Contracting State from taxing according to its law the income or profits from the business of any form of insurance. [Tax Convention, July 23, 1982, U.S.-N.Z., 35 U.S.T. (Part 2) 1949, 1964.]Page: Previous 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 Next
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