1. In accordance with the Provisions and subject to the limitations of the law of the United States (as it may be amended from time to time without changing the general principle hereof), the United States shall allow to a resident or citizen of the United States as a credit against the united States tax on income:
a) the income tax paid to Aruba by or on behalf of such citizen or resident; and
b) in the case of a United States company owning at least 10 Percent of the voting stock of a company which is a resident of Aruba and from which the United States company receives dividends, the income tax paid to Aruba by or on behalf of the distributing company with respect to the profits out of which the dividends are paid.
2. In accordance with the provisions and subject to the limitations of the law of Aruba (as it may be amended from time to time without changing the general principle hereof), Aruba may include in income items of income from sources in the United States, on the condition that Aruba allows a credit against the tax computed of an amount which bears the same ratio to that tax as the total amount of those items from sources in the United States bears to the total taxable income; provided, however, that the credit described in this sentence may be limited to a percentage of the tax computed before such credit so as to have the effect of imposing a minimum tax on income from sources in the United States.
3. For the purposes of allowing relief from double taxation pursuant to this Article, and subject to such source rules in the domestic laws of the Contracting States as apply solely for the purpose of limiting the foreign tax credit, income shall be deemed to arise exclusively as follows:
a) income derived by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention (other than solely by reason of citizenship in accordance with paragraph 3 of Article 1 (General Scope)) shall be deemed to arise in that other State;
b) income derived by a resident of a Contracting State which may not be taxed in the other Contracting State in accordance with the Convention shall be deemed to arise in the first-mentioned State.
The rules of this paragraph shall not apply in determining credits against United States tax for foreign taxes other than the taxes referred to in paragraphs lb) and 2 of Article 2 (Taxes Covered).
