Permanent Establishment Can Be Created Through Agency Relationship, IRS Official Says

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…

2010 OUTLOOK: Heightened Scrutiny of Transfer Pricing to Continue Worldwide; Official Says Simultaneous Audits ‘on the Doorstep’

Tax authorities in 2010 will continue heightened scrutiny of intercompany transactions and, after successes with information sharing through the Joint International Tax Shelter Information Centre, are expected to…

U.S. officials discuss permanent establishments in tax disputes

U.S. government officials Dec. 10 expressed dedication to a high permanent establishment threshold while revealing stepped-up efforts to find foreign taxpayers who may have created PEs in the United States…