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

Volume 3 No 2   |   Read Article

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

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 →