The Resource Analysis of construction PEs under U.S. income tax treaties

Analysis of construction PEs under U.S. income tax treaties

Label
Analysis of construction PEs under U.S. income tax treaties
Title
Analysis of construction PEs under U.S. income tax treaties
Creator
Subject
Language
eng
Summary
The issues discussed in this article often arise in connection with construction PEs under U.S. income tax treaties: (1) Which activities are covered by the significant duration test? a. What is a 'building site? or 'construction' or 'installation' project? b. Is there a difference between project and site? (2) What is the impact of support offices maintained by the construction contractor? (3) How is the duration of a project or site determined? a. When does a project start? Do engineering, procurement, construction manager, or construction subcontractors performing services in-country and on site start the clock? Do engineering, procurement, construction manager, or construction subcontractors performing services in-country but not on site start the clock? b. When does a project end? Do follow-up contracts toll the end date of the clock? c. What is the impact of subcontractors working on the same project? d. What is the impact of interruptions? (4) Aggregation of contracts: a. When are projects geographically coherent? b. When are projects commercially coherent?
Citation source
In: Journal of international taxation. - New York. - Vol. 20 (2009),
http://library.link/vocab/creatorName
  • Gordon, L.B
  • Peressada, A.N
  • Hester, L.A
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • PE
  • construction project
  • tax treaty
Label
Analysis of construction PEs under U.S. income tax treaties
Instantiates
Publication
Label
Analysis of construction PEs under U.S. income tax treaties
Publication

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