The tribunal held that gains from sale of shares did not fall under Article 14(4). It ruled that Article 14(6) applies, making gains taxable only in the country of residence. The decision clarifies ...
The ITAT clarified that Article 13(3A) applies strictly to shares and not to derivative instruments. It held that derivative gains fall under residual provisions and are taxable in the resident ...
New Jersey’s revised custody statute, N.J.S.A. 9:2-4, as amended by S4510/A5761, effective January 2026, sharpens the court’s framework for distinguishing legitimate child-safety concerns from ...
Furthermore, within each of these categories, a separate foreign tax credit calculation is required for each foreign country a taxpayer has paid an income or profits tax. The maximum amount of each ...
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