A little idea about the dividends US-SA tax treaty :"The Convention establishes maximum rates of tax that may be imposed by the source country on specified categories of income, including dividends, interest, and royalties, to residents of the other country that are the same as those in the U.S. model treaty and in many recent conventions with OECD countries. Pursuant to Article 10, dividends from direct investments are subject to tax by the source country at a rate of five per cent. The threshold ownership criterion for direct investment is ten per cent, consistent with other modern U.S. treaties, in order to facilitate direct investment. Other dividends are generally taxable by the source country at 15 per cent.
In general, under Article 11, interest derived and beneficially owned by a resident of a
Contracting State is exempt from tax by the source country and may be taxed only in the State in which the owner of the income resides. Under Article 12, royalties derived and beneficially owned by a resident of a Contracting State may also be taxed only in the State in which the owner of the income resides.
These rates of taxation on royalty and interest income do not apply, however, if the beneficial owner of the income is not a resident of, but carries on business in the source country and the income is attributable to a permanent establishment in the source country. In that situation, the income is to be considered either business profit or income from independent personal services and is subject to the provisions of Articles 7 and 14, which deal with these classes of income.
Like other U.S. tax treaties, this Convention provides the standard anti-abuse rules for certain classes of investment income in Articles 10 and 11.
The taxation of capital gains, described in Article 13 of the Convention, follows the pattern of the U.S. model tax treaty. It provides that gains from the sale of real property (including a U.S. real property interest) are taxable in the State in which the property is situated. Gains from the sale of personal property that is part of a permanent establishment or fixed base may be taxed in the State in which the permanent establishment or fixed base is located. The proposed Convention permits taxation of profits from international carriage by ships or airplanes only by the country of residence. Gains, including gains from the sale of ships, aircraft, or containers operated or used in international traffic are taxable only in the Contracting State in which the alienator is located."

A little idea about the dividends US-SA tax treaty :"The Convention establishes maximum rates of tax that may be imposed by the source country on specified categories of income, including dividends, interest, and royalties, to residents of the other country that are the same as those in the U.S. model treaty and in many recent conventions with OECD countries. Pursuant to Article 10, dividends from direct investments are subject to tax by the source country at a rate of five per cent. The threshold ownership criterion for direct investment is ten per cent, consistent with other modern U.S. treaties, in order to facilitate direct investment. Other dividends are generally taxable by the source country at 15 per cent.
In general, under Article 11, interest derived and beneficially owned by a resident of a
Contracting State is exempt from tax by the source country and may be taxed only in the State in which the owner of the income resides. Under Article 12, royalties derived and beneficially owned by a resident of a Contracting State may also be taxed only in the State in which the owner of the income resides.
These rates of taxation on royalty and interest income do not apply, however, if the beneficial owner of the income is not a resident of, but carries on business in the source country and the income is attributable to a permanent establishment in the source country. In that situation, the income is to be considered either business profit or income from independent personal services and is subject to the provisions of Articles 7 and 14, which deal with these classes of income.
Like other U.S. tax treaties, this Convention provides the standard anti-abuse rules for certain classes of investment income in Articles 10 and 11.
The taxation of capital gains, described in Article 13 of the Convention, follows the pattern of the U.S. model tax treaty. It provides that gains from the sale of real property (including a U.S. real property interest) are taxable in the State in which the property is situated. Gains from the sale of personal property that is part of a permanent establishment or fixed base may be taxed in the State in which the permanent establishment or fixed base is located. The proposed Convention permits taxation of profits from international carriage by ships or airplanes only by the country of residence. Gains, including gains from the sale of ships, aircraft, or containers operated or used in international traffic are taxable only in the Contracting State in which the alienator is located."

A little idea about the dividends US-SA tax treaty :"The Convention establishes maximum rates of tax that may be imposed by the source country on specified categories of income, including dividends, interest, and royalties, to residents of the other country that are the same as those in the U.S. model treaty and in many recent conventions with OECD countries. Pursuant to Article 10, dividends from direct investments are subject to tax by the source country at a rate of five per cent. The threshold ownership criterion for direct investment is ten per cent, consistent with other modern U.S. treaties, in order to facilitate direct investment. Other dividends are generally taxable by the source country at 15 per cent.
In general, under Article 11, interest derived and beneficially owned by a resident of a
Contracting State is exempt from tax by the source country and may be taxed only in the State in which the owner of the income resides. Under Article 12, royalties derived and beneficially owned by a resident of a Contracting State may also be taxed only in the State in which the owner of the income resides.
These rates of taxation on royalty and interest income do not apply, however, if the beneficial owner of the income is not a resident of, but carries on business in the source country and the income is attributable to a permanent establishment in the source country. In that situation, the income is to be considered either business profit or income from independent personal services and is subject to the provisions of Articles 7 and 14, which deal with these classes of income.
Like other U.S. tax treaties, this Convention provides the standard anti-abuse rules for certain classes of investment income in Articles 10 and 11.
The taxation of capital gains, described in Article 13 of the Convention, follows the pattern of the U.S. model tax treaty. It provides that gains from the sale of real property (including a U.S. real property interest) are taxable in the State in which the property is situated. Gains from the sale of personal property that is part of a permanent establishment or fixed base may be taxed in the State in which the permanent establishment or fixed base is located. The proposed Convention permits taxation of profits from international carriage by ships or airplanes only by the country of residence. Gains, including gains from the sale of ships, aircraft, or containers operated or used in international traffic are taxable only in the Contracting State in which the alienator is located."

A little idea about the dividends US-SA tax treaty :"The Convention establishes maximum rates of tax that may be imposed by the source country on specified categories of income, including dividends, interest, and royalties, to residents of the other country that are the same as those in the U.S. model treaty and in many recent conventions with OECD countries. Pursuant to Article 10, dividends from direct investments are subject to tax by the source country at a rate of five per cent. The threshold ownership criterion for direct investment is ten per cent, consistent with other modern U.S. treaties, in order to facilitate direct investment. Other dividends are generally taxable by the source country at 15 per cent.
In general, under Article 11, interest derived and beneficially owned by a resident of a
Contracting State is exempt from tax by the source country and may be taxed only in the State in which the owner of the income resides. Under Article 12, royalties derived and beneficially owned by a resident of a Contracting State may also be taxed only in the State in which the owner of the income resides.
These rates of taxation on royalty and interest income do not apply, however, if the beneficial owner of the income is not a resident of, but carries on business in the source country and the income is attributable to a permanent establishment in the source country. In that situation, the income is to be considered either business profit or income from independent personal services and is subject to the provisions of Articles 7 and 14, which deal with these classes of income.
Like other U.S. tax treaties, this Convention provides the standard anti-abuse rules for certain classes of investment income in Articles 10 and 11.
The taxation of capital gains, described in Article 13 of the Convention, follows the pattern of the U.S. model tax treaty. It provides that gains from the sale of real property (including a U.S. real property interest) are taxable in the State in which the property is situated. Gains from the sale of personal property that is part of a permanent establishment or fixed base may be taxed in the State in which the permanent establishment or fixed base is located. The proposed Convention permits taxation of profits from international carriage by ships or airplanes only by the country of residence. Gains, including gains from the sale of ships, aircraft, or containers operated or used in international traffic are taxable only in the Contracting State in which the alienator is located."