ARTICLE 2

General Definitions

In this Convention, unless the context otherwise requires:

(a) (i) The term ''United States'' means the United States of America; and (ii) When used in a geographical sense, the term ''United States'' means the states thereof and the District of Columbia. (b) (i) The term "Philippines'' means the Republic of the Philippines; and (ii) When used in a geographical sense, the term "Philippines" means the territory comprising the Republic of the Philippines. (c) The term "Contracting State" means the United States or the Philippines, as the context requires.

(d) The term "person" includes an individual, a partnership, a corporation, an estate, or a trust.

(e) (i) The term "United States corporation" means a corporation (or any unincorporated entity treated as a corporation for United States tax purposes) which is created or organized in or under the laws of the United States or any state thereof or the District of Columbia; and (ii) The term "Philippine corporation" means a corporation (or any unincorporated entity treated as a corporation for Philippine tax purposes) which is created or organized in the Philippines or under its laws. (f) (i) The term "competent authority" means: In the case of the United States, the Secretary of the Treasury or his delegate, and (ii) In the case of the Philippines, the Secretary of Finance or his delegate. (g) The term ''tax'' means tax imposed by the United States or the Philippines, whichever is applicable, to which this Convention applies by virtue of Article 1 (Taxes Covered).

(h) The term "international traffic" means any transport by a ship or aircraft operated by a resident of one of the Contracting States except where such transport is confined solely to places within a Contracting State.

(2) Any other term used in this Convention and not defined in this Convention shall, unless the context otherwise requires, have the meaning which it has under the laws of the Contracting State whose tax is being determined. Notwithstanding the preceding sentence, if the meaning of such a term under the laws of one of the Contracting States is different from the meaning of the term under the laws of the other Contracting State, or if the meaning of such a term is not readily determinable under the laws of one of the Contracting States, the competent authorities of the Contracting States may, in order to prevent double taxation or to further any other purpose of this Convention, establish a common meaning of the term of the purposes of this Convention.