ARTICLE 1. TAXES COVEBED

This Article designates the taxes of the respective States which are the sub­ ject of the proposed Convention. With respect to the United States, the taxes ineluded are the United States Federal Income taxes imposed by the Internal Revenue Code. This includes, for example, the surtax and would also include such taxes as the temporary surcharge which was in force from 1968 to 1970. However, the Convention is not intended to apply to taxes which are in the na­ ture of a penalty such as the taxes imposed under section 531 (accumulated earnings tax) and section 541 (personal holding company tax) of the Internal Revenue Code. These two taxes were expressly excluded to avoid uncertainty as to their status.

With respect to Trinidad and Tobago, the taxes Included are the corporation tax and the Income tax.

Pursuant to paragraph (2) of this Article the proposed Convention would also apply to taxes substantially similar to those enumerated which are imposed, in addition to or in place of the existing income taxes, after the date of signature

of this Convention (January 9,1970).

For purposes of Article 6 (Nondiscrimination) the Convention applies to taxes of every kind which are, or may be, imposed by the respective States, at the na­ tional, State, or local level.