1378 TREATIES [60 STAT. The income tax (including surtax), the excess profits tax and the national defense contribution (hereinafter referred to as United Kingdom tax). (2) The present Convention shall also apply to any other taxes of a substantially similar character imposed by either Contracting Party subsequently to the date of signature of the present Conven- tion or by the government of any territory to which the present Con- Pot, p. 1387. vention is extended under Article XXII. ARTICLE II "United States." "United Kingdom. " "Territory of one of the Contracting Par- ties." "United States cor- poration. " "United Kingdom corporation." "Corporation ofone Contracting Party." " Resident of the United Kingdom. " "Resident of the United States. " (1) In the present Convention, unless the context otherwise requires: (a) The term "United States" means the United States of America, and when used in a geographical sense means the States, the Territories of Alaska and of Hawaii, and the District of Columbia. (b) The term "United Kingdom" means Great Britain and Northern Ireland, excluding the Channel Islands and the Isle of Man. (c) The terms"territory of one of the Contracting Parties" and "territory of the other Contracting Party" mean the United States or the United Kingdom as the context requires. (d) The term "United States corporation" means a corpora- tion, association or other like entity created or organized in or under the laws of the United States. (e) The term "United Kingdom corporation" means any kind of juridical person created under the laws of the United Kingdom. (f) The terms "corporation of one Contracting Party" and "corporation of the other Contracting Party" mean a United States corporation or a United Kingdom corpora- tion as the context requires. (g) The term "resident of the United Kingdom" means any person (other than a citizen of the United States or a United States corporation) who is resident in the United Kingdom for the purposes of United Kingdom tax and not resident in the United States for the purposes of United States tax. A corporation is to be regarded as resident in the United Kingdom if its business is managed and con- trolled in the United Kingdom. (h) The term "resident of the United States" means any in- dividual who is resident in the United States for the pur- poses of United States tax and not resident in the United Kingdom for the purposes of United Kingdom tax, and any United States corporation and any partnership created or organized in or under the laws of the United States, being a corporation or partnership which is not resident in the United Kingdom for the purposes of United King- dom tax.
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