- 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.]
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