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Multijurisdictional tax final exam (emergency - has limited time!)
Finance & Accounting
Pages 9 (2259 words)
Part One – Jurisdiction to Tax Please read the following and answer the questions that follow. (15% of the total exam) A foreign corporation, Corporation A, decided to expand its operations from its incorporation jurisdiction in Country X to the US. In order to facilitate sales made to the US, Corporation A has rented space in a licensed public warehouse in Massachusetts where it stores some of its inventory.
Treaty with Country X PERMANENT ESTABLISHMENT 1. For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; and f) a mine, an oil or gas well, a quarry, or any other place of extraction of natural resources. 3. A building site or construction or installation project, or an installation or drilling rig or ship used for the exploration of natural resources, constitutes a permanent establishment only if it lasts, or the exploration activity continues for more than twelve months. 4. ...
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