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B.E.P.S. Initiative Spawns Unfavorable Permanent Establishment Court Decisions

Volume 3 No 2   /   Read Article

By Taketsugu Osada (guest author), Christine Long, and Stanley C. Ruchelman

Two court cases in different parts of the world attack tax plans premised on the absence of a permanent establishment. Pertinent U.S. income tax treaties, with Japan and India respectively, were effectively ignored in each case. Taketsugu Osada, Christine Long, and Stanley C. Ruchelman explain.  See more →