(1) In this Convention, unless the context otherwise requires:
(a) (i) The term "United States" means the United States of America; and
(ii) When used in a geographical sense, the term “United States”
means the
states thereof and the District of Columbia. Such term also includes:
(A) The territorial sea thereof, and
(B) The seabed and subsoil of the submarine areas adjacent to the
coast thereof, but beyond the territorial sea, over which the United States
exercises sovereign rights, in accordance with international law, for the purpose
of exploration and exploitation of the natural resources of such areas, but only
to the extent that the person, property, or activity to which this Convention is
being applied is connected with such exploration or exploitation.
(b) (i) The term “Korea” means the Republic of Korea; and
(ii) When used in a geographical sense, the term "Korea" means all the territory
in which the laws relating to Korean tax are in force. The term also includes:
(A) The territorial sea thereof, and
(B) The seabed and subsoil of the submarine areas adjacent to the
coast thereof, but beyond the territorial sea, over which Korea exercises
sovereign rights, in accordance with international law, for the purpose of
exploration and exploitation of the natural resources of such areas, but only to
the extent that the person, property, or activity to which this Convention is being
applied is connected with such exploration or exploitation.
(c) The term "Contracting State" means the United States or Korea, as the context
requires.
(d) The term "person" includes an individual, a partnership, a corporation, an estate, a
trust, or any body of persons.
(e) (i) The term "United States corporation" or "corporation of the United States"
means a corporation which is created or organized under the laws of the United
States or any state thereof or the District of Columbia, or any unincorporated
entity treated as a United States corporation for United States tax purposes;
and
(ii) The term "Korean corporation" or "corporation of Korea" means a
corporation (other than a United States corporation) which has its head or main office in
Korea, or any entity treated as a Korean corporation for Korean tax purposes.
(f) The term "competent authority" means:
(i) In the case of the United States, the Secretary of the Treasury or his
delegate, and
(ii) In the case of Korea, the Minister of Finance or his delegate.
(g) The term “State” means any National State, whether or not one of the Contracting
States.
(h) The term "citizen" means:
(i) In the case of the United States, a citizen of the United States, and
(ii) In the case of Korea, a national of Korea.