Subscribe to the Tax Headline RSS feed | Subscribe to the Tax Headline feed via EmailPermanent Establishment Can Be Created Through Agency Relationship, IRS Official Says
June 7, 2010 in Daily Tax Report · Leave a Comment
The activities of companies that send agents into other countries to do business can create a permanent establishment for tax purposes even if the presence of agents does not rise to the level of incorporation or putting in place significant facilities, an Internal Revenue Service official said June 4.
Steven Jensen, a senior international counsel in IRS’s Office of Chief Counsel, said some taxpayers take the position that “there is no agency P.E. It’s a unicorn. It doesn’t exist.”
Speaking to the Federal Bar Association Section of Taxation at an insurance conference, Jensen said, “We really don’t believe that. We believe P.E. is being created by agency activities.”
