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Multijurisdictional tax final exam (emergency - has limited time) - Coursework Example

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Multijurisdictional tax final exam (emergency - has limited time)

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. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or of collecting information, for the enterprise; e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; f) the maintenance of a fixed place of business solely for any combination of the activities mentioned in subparagraphs a) through e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character. MASSACHUSETTS LAW Except as otherwise provided in this section, every business corporation, organized under the laws of the commonwealth, or exercising its charter or other means of legal authority, or qualified to do business or actually doing business in the commonwealth, or owning or using any part or all of its capital, plant or any other property in the commonwealth, shall pay an income measure tax. A business corporation shall not be subject to the income measure of tax under if it is engaged in the business of selling tangible personal property and taxation of that business corporation under this chapter is precluded by the constitution or laws of the United States, or would be so precluded except for the fact that the business corporation stored tangible personal property in a licensed public storage warehouse, but no portion of any warehouse which is owned or leased by a consignor or consignee of the tangible personal property shall be considered a licensed public warehouse. 1. Does the treaty provision protect Corporation A from taxation by the US? Why or why not? The treaty provision protects Corporation A from taxation in the US on multiple fronts. Under regular Massachusetts law, any business that has a de minimis physical presence in the form of any assets, employees, contracted obligations, rented property etc. in Massachusetts is subject to taxation. This clause applies equally well to any foreign corporations doing ...Show more

Summary

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…
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