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CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED …

CONVENTION BETWEENTHE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THEGOVERNMENT OF THE UNITED KINGDOMOF GREAT BRITAIN AND NORTHERN IRELANDFOR THE AVOIDANCE OF DOUBLE TAXATION AND THEPREVENTION OF FISCAL EVASIONWITH RESPECT TO TAXES ON INCOME AND ON CAPITAL GAINSThe GOVERNMENT of the UNITED States of America and the GOVERNMENT of the UnitedKingdom of Great Britain and Northern Ireland,Desiring to conclude a new CONVENTION for the avoidance of double taxation and theprevention of fiscal evasion with respect to taxes on income and on capital gains,Have agreed as follows:2 ARTICLE 1 General Scope1.

the states thereof and the District of Columbia; such term also includes the territorial sea thereof and the sea bed and sub-soil of the submarine areas adjacent to that territorial sea, over which the United States exercises sovereign rights in accordance with international law; the term, however, does not include Puerto Rico, the Virgin Islands,

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