Pensions

ID: CCA_2010061408375619 Number: 201028038
Release Date: 7/16/2010
Office: ---
UILC: 894.11-00
From: ---
Sent: Monday, June 14, 2010 8:37:59 AM
To: ---
Cc: ---
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Subject: Treaty question
Under Art 3(2), the U.S. definition of "pensions and other similar remuneration" would apply. There's an argument that Art 18(1) might apply. However, based on the information we have, I think the much better view is that Art 15(1) applies.
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