ARTICLE 2
U.S. Income Tax Treaty — Trinidad Tax Treaty · 2026-10-03 edition · updated 2026-10-04 · United States
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. Such term also includes
(A) the territorial sea thereof and (B) the seabed and subsoil of the adjacent submarine areas beyond the territorial sea over which the United States exercises sovereign rights, in accordance with international law concerning the continental shelf, for the purpose of exploration and exploitation of the natural resources of such areas, but only to the extent that the person, property, or activity to which this Convention is being applied is connected with such exploration or exploitation. (b) (i) The term "Trinidad and Tobago" means the islands of Trinidad and Tobago; and
(ii) When used in a geographical sense, the term "Trinidad and Tobago" includes
(A) the territorial sea thereof and (B) the seabed and subsoil of the adjacent submarine areas beyond the territorial sea over which Trinidad and Tobago exercises sovereign rights, in accordance with Trinidad and Tobago legislation and international law concerning the continental shelf, for the purpose of exploration and exploitation of the natural resources of such areas, but only to the extent that the person, property, or activity to which this Convention is being applied is connected with such exploration or exploitation. (c) The terms "one of the Contracting States" and "the other Contracting State" mean the United States or Trinidad and Tobago, as the context requires.
(d) The term "person" comprises an individual, a corporation, and any other body of individuals or persons.
(e) The term "United States corporation" or "corporation of the United States" means a corporation or any entity treated as a corporation for United States tax purposes, which is created or organized under the laws of the United States or any State thereof or the District of Columbia.
(f) The term "Trinidad and Tobago corporation" or "corporation of Trinidad and Tobago" means any company or any entity treated as a company under Trinidad and Tobago tax law, which is resident within Trinidad and Tobago for purposes of Trinidad and Tobago tax.
(g) The term "resident of the United States" means:
(i) A United States corporation; or (ii) Any person (other than a corporation) resident in the United States for purposes of United States tax, but in the case of a partnership, estate, or trust only to the extent that the income derived by such person is subject to United States tax as the income of a resident. (h) The term "resident of Trinidad and Tobago" means:
(i) A Trinidad and Tobago corporation; or (ii) Any person (other than a corporation) resident in Trinidad and Tobago for purposes of Trinidad and Tobago tax, but in the case of a partnership, estate, or trust only to the extent that the income derived by such person is subjected to Trinidad and Tobago tax as the income of a resident.
(i) The term "competent authority" means:
(i) In the United States, the Secretary of the Treasury or his delegate; (ii) In Trinidad and Tobago, the Minister of Finance or his authorized representative. (j) The term "State" means any National State, whether or not one of the Contracting States.
(k) The terms "paid", "distributed", and "received" when used with respect to income shall include amounts "credited".
- As regards the application of the provisions of this Convention by one of the Contracting States, any term not defined in the Convention shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of this Convention. Notwithstanding the previous 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 further any other purpose of this Convention, establish a common meaning of the term for the purpose of this Convention by means of mutual agreement arrived at in accordance with Article 23 (Mutual Agreement Procedures).
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