1408 TREATIES [56 STAT. When an enterprise of one of the contracting States carries on business in the other contracting State through an employee or agent established there, who has general authority to contract for his employer or principal or has a stock of merchandise from which he regularly fills orders which he receives, such enterprise shall be deemed to have a permanent establishment in the latter State. The fact that an enterprise of one of the contracting States has business dealings in the other contracting State through a com- mission agent, broker or other independent agent or maintains therein an office used solely for the purchase of merchandise shall not be held to mean that such enterprise has a permanent estab- lishment in the latter State. "Minister," "com- 4. The term "Minister", as used in this Convention, means the missioner," "compe- tent authority." Minister of National Revenue of Canada or his duly authorized representative. The term "Commissioner", as used in this Conven- tion, means the Commissioner of Internal Revenue of the United States of America, or his duly authorized representative. The term "competent authority", as used in this Convention, means the Com- missioner and the Minister and their duly authorized representatives. "United states of 5. The term "United States of America", when used in a geographi- America." cal sense, includes only the States, the Territories of Alaska and "Canada." Hawaii, and the District of Columbia. The term "Canada" when used in a geographical sense means the Provinces, the Territories and Sable Island. "Subsidiary corpo- 6. The term "subsidiary corporation" referred to in Article XI of ration. " this Convention means a corporation all of whose shares (less directors' qualifying shares) having full voting rights are beneficially owned by another corporation, provided that ordinarily not more than one- quarter of the gross income of such subsidiary corporation is derived from interest and dividends other than interest and dividends re- ceived from its subsidiary corporations. "Rentals and royal- 7. (a) The term "rentals and royalties" referred to in Article II of this Convention shall include rentals or royalties arising from leasing real or immovable, or personal or movable property or from any interest in such property, including rentals or royalties for the use of, or for the privilege of using, patents, copyrights, secret proc- esses and formulae, goodwill, trade marks, trade brands, franchises and other like property; "Interest." (b) the term "interest", as used in this Convention, shall include income arising from interest-bearing securities, public obligations, mortgages, hypothecs, corporate bonds, loans, deposits and current accounts; "Dividends." (C) the term "dividends", as used in this Convention, shall include all distributions of the earnings or profits of corporations. "Pensions." 8. The term "pensions" referred to in Article VI of this Convention means periodic payments made in consideration for services rendered or by way of compensation for injuries received.
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