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`ANNEX`

qualified under the tax laws of both the United States and Japan. In the third…

U.S. Income Tax Treaty — Technical Explanation - 2003 · 2026-10-03 edition · updated 2026-10-04 · United States

the stock option is regarded as nonqualified under the tax law of the United States, but is regarded as qualified under the tax law of Japan, In the fourth alternative,the stock option is regarded as nonqualified under the tax law of Japan, but is regarded as qualified under the tax law of the United States.

In cases resulting from the first and second alternatives, the rules in the Convention, in particular the rule included in paragraph 10 of the Protocol, that allocate taxingjurisdiction

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▸Contents — U.S. Income Tax Treaty — Technical Explanation - 2003

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