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This article examines some of the background to the 1954 Japan-United States Income Tax Treaty from a historical perspective.Japanese domestic law developed the “source” of income concept and implemented a foreign tax credit system during the three years of treaty negotiations. The 1954...
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The main purpose here is an inquiry into the applicability of tax conventions, especially in the context of the personal scope. In other words, to whom are tax conventions applicable? That question means the first step of the application of tax conventions.In general tax conventions (treaties)...
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