22 Mar 2016 NOTE: A taxpayer may decide annually to have eligible "active trade or business income" taxed at the reduced rate under SC Code Section ...
09- Company with an item of income that meets the active trade or business test Stock Ownership and Base Erosion. Test 07. Active. Business 09.
(Check only one; see test definitions on page 2):. The beneficial owner derives Company with an item of income that meets active trade or business test.
13 Dec 2016 (active trade or business) 4 (derivative benefits)
12 Aug 2015 If Trust A is engaged in business in Nevada within the meaning of ... Section 14.3: Clarify that the "active trade or business" test applies ...
19 Dec 2006 Active trade or business income or loss does not include: (a)(i) passive investment income as defined in Internal Revenue. Code Section 1362(d) ...
In principle this test requires the company to carry out an active trade or business in the Contracting State and that the income received from the US is
30 Nov 2020 trade or business in the United States to withhold tax on a ... effect and you meet the definition of “active NFFE”under.
https://www.irs.gov/pub/irs-trty/netherte04.pdf
in trade or business relates only to interpretation of tax convention and not to possibly wider meaning in some Code provisions). However it has been pointed