Well, well, well.....it is truly the end of the 48th tax season of my life. Last night I did the final 5 FinCEN 114 efile reports that are now a permanent fixture of an American tax filer's life. I'm sure I did some of those I filed incorrectly. Most of the client-prepared forms ....

TO a large extent, non-resident taxation depends on enforceability. Payments once gone out of India may be gone forever unless there is a mechanism for capturing the tax element in such payments. In that view of the matter, in case of payments to non-residents, failure to deduct tax at source in respect of ....

Chapter I of the OECD and UN Models of Tax Convention defines the scope of the respective conventions. While article 1 in the Chapter deals with 'persons covered', article 2 deals with 'taxes covered' and provides as under:

"1. This Convention shall apply to taxes on income and on capital ....