highest court(s): Supreme Court of Justice or Corte Suprema de Justicia (consists of the Civil-Agrarian and Labor Chambers each with 7 judges, and the Penal Chamber with 9 judges); Constitutional Court (consists of 9 magistrates); Council of State (consists of 27 judges); Superior Judiciary Council (consists of 13 magistrates)
judge selection and term of office: Supreme Court judges appointed by the Supreme Court members from candidates submitted by the Superior Judiciary Council; judges elected for individual 8-year terms; Constitutional Court magistrates - nominated by the president, by the Supreme Court, and elected by the Senate; judges elected for individual 8-year terms; Council of State members appointed by the State Council plenary from lists nominated by the Superior Judiciary Council
subordinate courts: Superior Tribunals (appellate courts for each of the judicial districts); regional courts; civil municipal courts; Superior Military Tribunal; first instance administrative courts
Betancourt, a dual French-Colombian citizen, made headlines when she was rescued in an army raid in 2008, after six years in captivity. But Rojas, who is now jumping back into Colombian politics, has an even more remarkable tale.
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(a) the individual shall be deemed to be a resident only of the State in which the individual has a permanent home available and if the individual has a permanent home available in both States, the individual shall be deemed to be a resident only of the State with which the individual's personal and economic relations are closer (centre of vital interests);
(b) if the State in which the individual's centre of vital interests is situated cannot be determined, or if there is not a permanent home available to the individual in either State, the individual shall be deemed to be a resident only of the State in which the individual has an habitual abode;
4. Where by reason of the provisions of paragraph 1 a person other than an individual or a company described in paragraph 3 is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention to such person. In the absence of such agreement, such person shall not be entitled to claim any relief or exemption from tax provided by the Convention.
(b) the furnishing of services, including consulting services, by an enterprise of a Contracting State through employees or other individuals engaged by the enterprise for such purposes in the other Contracting State, but only where such activities continue within that State for a period or periods aggregating more than 183 days within any twelve-month period.
3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematographic films or movies, tapes and other means of audio and video reproduction, patent, trade mark, design or model, plan, secret formula or process or other intangible property, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. The term "royalties" also includes payments received as consideration for the furnishing of technical assistance, technical services and consulting services. However, the term "royalties" does not include income dealt with in Article 8.
6. The provisions of paragraph 5 shall not affect the right of a Contracting State to levy, according to its law, a tax on gains from the alienation of any property, other than property to which the provisions of paragraph 7 apply, derived by an individual who is a resident of the other Contracting State and has been a resident of the first-mentioned State at any time during the six years immediately preceding the alienation of the property.
7. Where an individual who ceases to be a resident of a Contracting State, and immediately thereafter becomes a resident of the other Contracting State, is treated for the purposes of taxation in the first-mentioned State as having alienated a property and is taxed in that State by reason thereof, the individual may elect to be treated for purposes of taxation in the other State as if the individual had, immediately before becoming a resident of that State, sold and repurchased the property for an amount equal to its fair market value at that time. However, this provision shall not apply to property any gain from which, arising immediately before the individual became a resident of that other State, may be taxed in that other State nor to immovable property situated in a third State.
2. Where income in respect of personal activities exercised by an entertainer or a sportsperson in that individual's capacity as such accrues not to the entertainer or sportsperson personally but to another person, that income may, notwithstanding the provisions of Articles 7 and 14, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.
(b) the rate determined by reference to the amount of tax that the recipient of the payment would otherwise be required to pay for the year on the total amount of the periodic pension payments received by the individual in the year, if the individual were resident in the Contracting State in which the payment arises.
1. (a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.
(b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who:
Payments which a student or business apprentice who is, or was immediately before visiting a Contracting State, a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of that individual's education or training receives for the purpose of that individual's maintenance, education or training shall not be taxed in that State, if such payments arise from sources outside that State.
3. The Convention shall not apply to any company, trust or other entity that is a resident of a Contracting State and is beneficially owned or controlled, directly or indirectly, by one or more persons who are not residents of that State, if the amount of the tax imposed on the income or capital of the company, trust, partnership or other entity by that State is substantially lower than the amount that would be imposed by that State (after taking into account any reduction or offset of the amount of tax in any manner, including a refund, reimbursement, contribution, credit, or allowance to the company, trust or partnership, or to any other person) if all of the shares of the capital stock of the company or all of the interests in the trust or other entity, as the case may be, were beneficially owned by one or more individuals who were residents of that State.
2. Notwithstanding the provisions of Article 4, an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State that is situated in the other Contracting State or in a third State shall be deemed for the purposes of the Convention to be a resident only of the sending State if that individual is liable in the sending State to the same obligations in relation to tax on total income as are residents of that sending State.
3. Contributions in a year in respect of services rendered in that year paid by, or on behalf of, an individual who is a resident of a Contracting State or who is temporarily present in that State to a pension plan that is recognized for tax purposes in the other Contracting State shall, during a period not exceeding in the aggregate 60 months, be treated in the same way for tax purposes in the first-mentioned State as a contribution paid to a pension plan that is recognized for tax purposes in that first-mentioned State, if
(a) such individual was contributing on a regular basis to the pension plan for a period ending immediately before that individual became a resident of or temporarily present in the first-mentioned State; and
(h) Paragraphs 6 and 7 of Article 13 are included in the Convention in view of Canada's domestic rules regarding taxpayer migration. At the time of the signature of the Convention, Colombia has no similar domestic rules and, therefore, it is anticipated that these paragraphs will initially only apply in the case of an individual who ceases to be a resident of Canada.
Should he make his debut on Saturday, Berlin-born midfielder Lenny Maloney would become the latest German-American player to suit up for the United States. Since 1990, a total of 16 German-born dual nationals have earned at least one cap for the USMNT. Seven of those players have represented the United States at a World Cup, with two serving as captain: John Brooks, Timmy Chandler, Thomas Dooley (c), Julian Green, Fabian Johnson, Jermaine Jones, Mike Windischmann (c).
6 Battery life varies significantly with settings, usage and other factors. Based on results from internal lab tests for local video playback time conducted by Samsung. Test Results from a prerelease version of the device under default settings (audio volume and brightness levels) without connection to Wi-Fi or mobile network. Battery life varies significantly with settings, usage and other factors.
The movie's two major white characters are loosely based on real individuals. One is the German ethnologist Theodor Koch-Grunberg, who in the early 20th century explored the Yapura River and the Rio Negro to the border with Venezuela. The other is the American psychedelic researcher and botanist Richard Evans Schultes, who studied Amazonian ethno-botany in the 1940s. The earlier researcher is named Theo here, and played by Jan Bijvoet of Borgman. He arrives in the story suffering from malaria and requiring homegrown medicine and a certain amount of nursing and hand-holding. The other character has been named Evan (Brionne Davis), an American who is searching for a plant called yakruna, which grows on rubber plants and improves their quality; he seems to be retracing Theo's route, and even has some of his journals in a knapsack.
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