The Resource When do foreign reinsurance activities in the United States constitute a permanent establishment?

When do foreign reinsurance activities in the United States constitute a permanent establishment?

Label
When do foreign reinsurance activities in the United States constitute a permanent establishment?
Title
When do foreign reinsurance activities in the United States constitute a permanent establishment?
Creator
Subject
Summary
This article deals with the question of whether certain Japanese insurance companies that reinsured risks in the US, actually had taxable permanent establishments in the US. The author discusses both the companies's and IRS's position on the issue. Special attention is given to the US-Japan Convention and the dependent agency relationship
Citation source
In: Tax notes international. - Arlington. - Vol. 5 (1992),
http://library.link/vocab/creatorName
Turro, J
Language note
English
http://library.link/vocab/subjectName
  • insurance company
  • PE
  • agency
  • tax treaty
Label
When do foreign reinsurance activities in the United States constitute a permanent establishment?
Instantiates
Publication
Label
When do foreign reinsurance activities in the United States constitute a permanent establishment?
Publication

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