ARTICLE 14
U.S. Income Tax Treaty — egypt tax treaty documents: egypt.pdf · 2026-10-03 edition · updated 2026-10-04 · United States
Capital Gains
(1) A resident of one of the Contracting States shall be exempt from tax by the other Contracting State on gains from the sale, exchange, or other disposition of capital assets unless (a) The gain is derived by a resident of one of the Contracting States from the sale, exchange, or other disposition of property described in Article 7 (Income from Real Property) situated within the other Contracting State,
(b) The gain arises out of a sale, exchange, or other disposition described in paragraph (2)(b) of Article 13 (Royalties),
(c) The gain is treated, under paragraph (6) of Article 8 (Business Profits), as industrial or commercial profits attributable to a permanent establishment which the recipient has in such other Contracting State, or
(d) The recipient of the gain, being an individual who is a resident of one of the Contracting States is present in the other Contracting State for a period or periods aggregating 183 days or more during the taxable year.
(2) In the case of gains described in paragraph (l)(a), the provisions of Article 7 (Income from Real Property) shall apply. In the case of gains described in paragraph (1)(b), the provisions of Article 13 (Royalties) shall apply. In the case of gains described in paragraph (l)(c), the provisions of Article 8 (Business Profits) shall apply.
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