Page:United States Statutes at Large Volume 60 Part 2.djvu/306

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[60 STAT. "United States. " "Great Britain." "Territory." "Tax." Doetermination of (1) For the purposes of the present Convention, the question whether a decedent was domiciled in any part of the territory of one of the Contracting Parties at the time of his death shall be determined in accordance with the law in force in that territory. (2) Where a person dies domiciled in any part of the territory of one Contracting Party, the situs of any of the following rights or interests, legal or equitable, which for the purposes of tax form part of the estate of such person or pass on his death, shall, for the purposes of the imposition of tax and for the purposes of the credit to be allowed Pot, p.194 under Article V, be determined exclusively in accordance with the following rules, but in cases not within such rules the situs of such rights and interests shall be determined for those purposes in accord- ance with the law relating to tax in force in the territory of the other Contracting Party: (a) Rights or interests (otherwise than by way of security) in or over immovable property shall be deemed to be situated at the place where such property is located; (b) Rights or interests (otherwise than by way of security) in or over tangible movable property, other than such property for which specific provision is hereinafter made, and in or over bank or currency notes, other forms of currency recog- nized as legal tender in the place of issue, negotiable bills of exchange and negotiable promissory notes, shall be deemed to be situated at the place where such property, notes, cur- rency or documents are located at the time of death, or, if in transitu,at the place of destination; ARTICLE II (1) In the present Convention, unless the context otherwise requires: (a) The term "United States" means the United States of Amer- ica, 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 "Great Britain" means England, Wales and Scot- land, and does not include the Channel Islands or the Isle of Man. (c) The term "territory" when used in relation to one or the other Contracting Party means the United States or Great Britain, as the context requires. (d) The term "tax" means the estate duty imposed in Great Britain or the United States Federal estate tax, as the context requires. (2) In the application of the provisions of the present Convention by one of the Contracting Parties, any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting Party relating to the taxes which are the subject of the present Convention. ARTICLE III 1392 TREATIES