PERMANENT ESTABLISHMENT IN THE UNITED STATES: A VIEW THROUGH ARTICLE V OF THE U.S.-CANADA TAX TREATY

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By Martin B. Tittle The last time someone wrote comprehensively about permanent establishment in the United States, the catchwords of the day were Mayaguez, Watergate, and Squeaky Fromme. At that time, there were only nine U.S. cases and thirteen revenue rulings addressing permanent establishment...

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