26 CFR 513.2 - Dividends.
The fact that the payee of the dividend is not required to pay Irish tax on such dividend because of the application of reliefs or exemptions under Irish revenue laws does not prevent the application of the reduction in rate of United States tax with respect to such dividend. If the dividend would have been subject to Irish tax had the payee thereof derived an income large enough to require payment of tax then liability to Irish tax exists for the purpose of the reduction in rate of United States tax. As to what constitutes a permanent establishment, see Article II(1)(i) of the convention.
- 26 CFR 513.3 — Interest.
- 26 CFR 513.11 — Refund of Income Tax Withheld During 1951.
- 26 CFR 513.4 — Patent and Copyright Royalties and Film Rentals.
- 26 CFR 513.7 — Release of Excess Tax Withheld at Source.
- 26 CFR 513.8 — Addressee Not Actual Owner.
- 26 CFR 513.5 — Natural Resource Royalties and Real Property Rentals.