The general rule in the 1980 Convention regarding the taxation of gains from the alienation of any property is that such gains are taxable only in the state of residency of the alienator. |
Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident. |
The participants reported that primary custody was given to the mother at the onset of divorce, regardless of who later became the alienator and who became the lost parent. |
Fear, dependence on and identification with the alienator play an important role. |
For instance, a mother of the alienator will be more likely to alienate as well. |
Expenses on the maintenance of the alienator made by the alienee before the cancellation of the contract shall not be reimbursed. |