Comments on U.S.-Canada Fifth Protocol and OECD Services Draft

Worldwide Tax Daily, Vol. 2008, pp. 45-49, 2008

5 Pages Posted: 2 Aug 2008

Date Written: March 5, 2008

Abstract

This practitioner Article first summarizes the public comments of the New York State Bar Association, Ernst & Young, BDO Seidman, and the Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants regarding the Fifth Protocol to the U.S.-Canada tax treaty. It then selects and discusses six themes that appear in the eleven comments received by the OECD regarding its proposed extension of the concept of permanent establishment to certain service providers.

Keywords: tax, tax treaty,United States,U.S.,Canada,protocol,Fifth Protocol,New York State Bar Association,NYSBA,Ernst & Young,E&Y,BDO Seidman,Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants,OECD,permanent establishment,PE,services,services draft

JEL Classification: K33, K34

Suggested Citation

Tittle, Martin B., Comments on U.S.-Canada Fifth Protocol and OECD Services Draft (March 5, 2008). Worldwide Tax Daily, Vol. 2008, pp. 45-49, 2008, Available at SSRN: https://ssrn.com/abstract=1195718

Martin B. Tittle (Contact Author)

Law Office of Martin B. Tittle ( email )

P.O. Box 1541
Ann Arbor, MI
United States
734-846-3864 (Phone)

HOME PAGE: http://www.martintittle.com

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