Sources of Income. For the purposes of this Agreement -
Sources of Income. Income derived by a resident of one of the Contracting States which, under any one or more of Articles 6 to 8, 10 to 16 and 18, may be taxed in the other Contracting State shall for the purpose of Article 23, and of the income tax law of that other State, be deemed to be income from sources in that other State.
Sources of Income. 1. For the purposes of this Agreement -
(i) dividends paid by a company which is resident in Singapore for the purposes of Singapore tax to a New Zealand resident shall be treated as income from sources in Singapore;
(ii) dividends paid by a Malaysian company out of profits derived from sources in Singapore to a New Zealand resident shall be treated as income from sources in Singapore;
(b) dividends paid by a company which is resident in New Zealand for the purposes of New Zealand tax to a Singapore resident shall be treated as income from sources in New Zealand;
(c) profits derived by a resident of a Contracting State from the operation of ships or aircraft, being profits from operations confined solely to places in the other Contracting State, shall be treated as having a source in that other Contracting State;
(d) interest shall be treated as having a source in a Contracting State where the person paying the interest is the Government of that Contracting State or a resident of that Contracting State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment and the interest is borne by such permanent establishment, then such interest shall be treated as having a source in the Contracting State in which the permanent establishment is situated;
(e) royalties (as defined in Article 10) and payments referred to in subparagraph (j)(ii), subparagraph (j)(iii) or subparagraph (j)(iv) of paragraph 1 of Article 2 shall be treated as having a source in a Contracting State where the person paying such royalties or making such payments is the Government of that Contracting State or a resident of that Contracting State. Where, however, the person paying such royalties or making such payments, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment and such royalties or payments are borne by such permanent establishment, then such royalties or payments shall be treated as having a source in the Contracting State in which the permanent establishment is situated;
(f) natural resource royalties and income referred to in subparagraph (j)(v), subparagraph (j)(vi) or subparagraph (j)(vii) of paragraph 1 of Article 2 derived by a resident of a Contracting State shall be treated as derived from sources in the other Contracting State if the land, mine, quarry, natural resource, standing timber or rent-producing property is sit...
Sources of Income. At least 75% of the gross income of the Partnership is derived from rents from real property and other real estate related sources of income specified in Section 856(c)(3) of the Code. At least 95% of the gross income of the Partnership is derived from dividends, interest, rents from real property, and other passive sources of income specified in Section 856(c)(2) of the Code.
Sources of Income. None of the Company and the WFOE shall have more than fifty percent (50%) of its assets in a passive form (i.e., cash) and receive more than seventy-five percent (75%) of its total income from passive sources (i.e., interest or fees generated from leasing of equipment). The terms of passive form and passive sources shall have the meanings indicated in Section 1297 of the United States Internal Revenue Code of 1986. The Company shall, and shall cause each Group Company to, use its best efforts to ensure that the Company and each Group Company arrange their affairs, including taking such restructuring steps as may be necessary, to implement the most tax advantageous structure for the Company and each Group Company, including without limitation, to ensure that the Company will not be treated as a “passive foreign investment company” within the meaning of section 1297 of the United States Internal Revenue Code of 1986.
Sources of Income. PERIODIC PAYMENTS CANNOT BE ORDERED FROM THE FOLLOWING SOURCES OF INCOME (subject to some exceptions):
Sources of Income. If applicable to your appointment, the sources of income to compensate you for the duties associated with your appointment are more particularly set out in Appendix “A” attached to this Agreement.
Sources of Income. The Fund will receive proceeds primarily by way of cash dividends, interest or other forms of cash receivable as may be permitted by law from the Portfolio Investments, returns / yield on Portfolio Investments and cash proceeds realized from the disposition of the Fund’s Investments and gains from the Portfolio Investments (“Investment Proceeds”). Amounts held by the Fund pending investment or distribution or as Operating Reserves shall be held in liquid mutual funds or bank deposits or other liquid assets of high quality such as Triparty Repo Dealing and Settlement, Commercial Papers, Certificates of Deposits, etc., to the extent permitted under the AIF Regulations (“Temporary Investments”). The Investment Manager shall cause the Fund to distribute proceeds attributable to any Temporary Investment to the Contributors pro rata based on their Investment Proportions. The income earned from Temporary Investments made, if any, for the period commencing from the date of receipt of monies for each Drawdown Notice (issued to the Contributor) and ending with the date of the Fund Investment, shall not form part of the Investment Proceeds and the same shall be distributed to the Contributor in proportion to its related Capital Contribution for the relevant Drawdown Notice.
Sources of Income. The sources of income of the Company shall be such initial charges and such fees as may be fixed by the Board of Directors; and such premiums for insurance coverage ratably levied by the Board of Directors against the membership as may be required (1) to pay accrued liabilities, or (2) to meet anticipated needs of the Company, or (3) to restore the financial reserves.
Sources of Income. This is a voluntary position and as such, Dr. will derive no income from this appointment. Some specific contributions to education may be recognized with a stipend from the Faculty; Dr. will be eligible for such Faculty stipends, as are all other Faculty members. Any stipend received is without University fringe benefits or tenure. Stipends associated with departmental practice plans are available only to members of those specific practice plans.
