TaxConnections

 
 

Access Leading Tax Experts And Technology
In Our Global Digital Marketplace

Please enter your input in search

Email   Contact Us

Tag Archive for The Freeman Law International Tax Symposium

U.S. Tax Treaties: What Is A Permanent Establishment? What Activities Are Generally Not A Permanent Establishment?

U.S. Tax Treaties: What Is A Permanent Establishment? What Activities Are Generally Not A Permanent Establishment?

The Tax Risk Of Permanent Establishment

Recent  developments, such as the Tax Cuts & Jobs Act (TCJA) and the OECD’s Base Erosion and Profits Shifting (BEPS) initiative, have forced multinational businesses to re-evaluate global strategies and the tax impact of doing business abroad.   Navigating the risk of a permanent establishment remains among the most important international tax risks.

While a nonresident alien or foreign corporation engaged in a trade or business in the United States is generally subject to taxation on its net taxable income that is effectively connected with the conduct of the U.S. trade or business, the rules are different (or at least, can be) when a resident of a treaty country conducts the business.  Where a tax treaty is applicable, the concept of a permanent establishment—and whether income is attributable to that permanent establishment—replaces the concept of effectively connected income as the governing standard.

Read more

The Freeman Law International Tax Symposium

The Freeman Law International Tax Symposium

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation.

We have assembled leading experts from across the world, along with key government officials and other industry leaders, setting the stage for unparalleled thought leadership—all delivered in a format made for 2021 and beyond. Learn from recognized leaders, as we discuss:

  • Global Tax Reform
  • International Civil Penalty Enforcement
  • International Criminal Tax Enforcement
  • The Untold Story of Swiss Bank Secrecy and a
    revolutionary Era of International Tax Enforcement
  • Transfer Pricing Developments
  • A Closer Look at GILTI and FDII
  • Cryptocurrency – Global Enforcement Trends
  • The Tax Information Age—Global Information Exchange
  • Cross-Border Tax Planning Opportunities

For more information and to register, see our International Tax Symposium page.