Permanent Establishment in the United States -- A View Through Article V of the U.S.-Canada Tax Treaty

Vandeplas Publishing - November 2007

32 Pages Posted: 16 Dec 2014

Date Written: November 16, 2007

Abstract

The last time someone wrote comprehensively about permanent establishment in the United States, the catchwords of the day were Mayaguez, Watergate, and Squeaky Fromme. At that time, there were only nine U.S. cases and thirteen revenue rulings addressing permanent establishment. Perhaps not surprisingly, over a third of those authorities addressed the U.S.-Canada tax treaty.

This book provides a fresh look at "PE in the U.S." using the U.S.-Canada treaty as a case study. It also illustrates a methodology that can be applied to the study of other treaty concepts.

Until September 2007, the treaty with Canada was fairly representative of late-twentieth-century U.S. tax treaties. The protocol signed on September 21 made it cutting-edge in many respects, and the creation of a new "services PE" was one of the innovative changes that Tittle explores in this book.

Keywords: permanent establishment, tax treaty, Canada, United States

JEL Classification: H25, K33, K34

Suggested Citation

Tittle, Martin B., Permanent Establishment in the United States -- A View Through Article V of the U.S.-Canada Tax Treaty (November 16, 2007). Vandeplas Publishing - November 2007, Available at SSRN: https://ssrn.com/abstract=2538166

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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