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Paragraph 4 provides a derivative benefits test under which a Netherlands company may be entitled to the benefits of the Convention with respect to Articles 10 ( Dividends ) , 11 ( Branch Tax ) , 12 ( Interest ) and 13 ( Royalties ) . The Asian Pacific American Network ( APAnet ) is a broad-based coalition of community-based organizations ( CBOs ) that acts as a catalyst to develop and promote the application of computer information technologies relevant to the needs and perspectives of Asian and Pacific Islanders Americans . The following items of income are specified : U.S. situs real property taxable by the united States under Article 6 ( Income from Real Property ) : profits attributable to a U.S. permanent establishment and taxable by the united States , to the extent such income is subject to united States tax under Article 7 ( Business Profits ) : dividends , interest , and royalties attributable to a U.S. permanent establishment or fixed base and , therefore , taxable on a net basis by the United states under paragraph 5 of Article 10 ( Dividends ) , paragraph 3 of Article 12 ( Interest ) or paragraph 3 of Article 13 ( Royalties ) , respectively : gains from the disposition of U.S. situs real property or a U.S. real property interest , or gain from the alienation of personal property forming part of the property of a U.S. permanent establishment or fixed base , and taxable in the United States under paragraphs 1 and 3 of Article 14 ( Capital Gains ) ; income from the performance of independent personal services in the United States , to the extent such income is subject to U.S. tax under Article 15 ( Independent Personal Services ) ; income from the performance of dependent personal services in the United States which is taxable by the United States under paragraph 1 of Article 16 ( Dependent Personal Services ) ; social security benefits taxable by the United States under paragraph 4 of Article 19 ( Pensions , Annuities , Alimony ) : remuneration and pensions for Government service taxable by the United States under Article 20 ( Government Service ) ; and income attributable to a permanent establishment or fixed base taxable by the United States under paragraph 2 of Article 23 ( Other Income ) . The recent passage of the National Instructional Materials Accessibility Standard ( NIMAS ) will be discussed as part of this presentation . Paragraph 3 of the Article elaborates on the following provisions : paragraphs 1 and 2 of Article 7 ( Business Profits ) , paragraph 5 of Article 10 ( Dividends ) , paragraph 3 et Article 12 ( Interest ) , paragraph 3 of Article 13 ( Royalties ) , paragraph 3 of Article 14 ( Capital Gains ) , paragraph 1 of Article 15 ( Independent Personal Services ) and paragraph 2 of Article 23 ( Other Income ) . A credit is allowed for dividends subject to U.S. withholding tax under paragraph 2 of Article 10 ( Dividends ) , and for directors ' fees and remuneration of entertainers and athletes subject to U.S. tax under Articles 17 ( Directors ' Fees ) and 18 ( Artistes and Athletes ) , respectively . Thus , if a U.S. citizen resident in the Netherlands receives U.S. source portfolio dividends , the Netherlands foreign tax credit would be limited to 15 percent of the dividend - - - the U.S. tax that may be imposed under subparagraph 2 ( b ) of Article 10 ( Dividends ) - - - even if the shareholder is subject ( before the special U.S. foreign tax credit and source rules provided for in subparagraphs 3 ( b ) and 3 ( c ) ) to a U.S. rate of tax of 36 percent because of his U.S. citizenship . The preference of the American committees for single-word terms ( mononyms ) where practicable , although recognized by a majority as desirable , has not thus far been widely adopted because of prejudice against barbaric combinations and in favour of adhering to historical priority .