An overview of the U.S. tax treaty definitions and their impact on permanent establishment, business profits, tax residency, hybrid entities and more.
Learning Objectives
Identify when a permanent establishment exists;Determine the attributable business profits to a permanent establishment;Recall how U.S. tax treaties determine U.S. tax residency and how it impacts eligibility under the treaty;Distinguish how hybrid entities are treated under U.S. income tax treaties;Determine the impact a US income tax treaty has on withholding taxes on FDAP;Apply the appropriate LOB clause to determine eligibility under a U.S. tax treaty;Identify the mechanisms for tax dispute resolution
Major Topics
Permanent establishment;Business profits;Tax residency;Hybrid entities;FDAP income;LOB clauses;Income resourcing;Foreign tax credits
