(Download) Permanent Establishment in the United States: A View Through Article V of the U.S.-Canada Tax Treaty (Tax Law) pdf by Martin B. Tittle

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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.
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