Rev. Rul. 69-139

Article I(1)(b)(i) of the Income Tax Convention between the United States and the Netherlands, T.D. 5778, C.B. 1950-1, 92, provides, that in the case of the Netherlands, the taxes which are the subject of the Convention are, for the application of the provisions of the Convention other than Article XX, (1) the income tax and the Netherlands tax credited against it, (2) the corporation tax and the Netherlands tax credited against it, (3) the property tax, and (4) the tax on fees of directors and managers of corporations.

Article XIX(2) of the Convention, as amended by Article XII of the Supplementary Income Tax Convention signed December 30, 1965, C.B. 1967-2, 472, at 478, provides, in part, that the United States shall allow a taxpayer of the United States as a credit against its tax specified in Article I(1)(a) of the Convention (Federal income taxes), the appropriate amount of taxes paid to the Netherlands.

Held, pursuant to the provisions of Article XIX(2) and Article I(1)(b)(i) of the Convention, the income tax, the corporation tax, the property tax, and the tax on fees of directors and managers of corporations imposed by the Netherlands are creditable taxes.