The U.S. IRS has released two international practice units concerning permanent establishment status, including:
- Creation of a Permanent Establishment (PE) through the Activities of a Dependent Agent in the United States, which examines whether a U.K. company has a U.S. permanent establishment as a result of an agent concluding contracts on its behalf in the United States; and
- Preparatory and Auxiliary Treaty Exception to Permanent Establishment Status, which focuses on whether an activity…