Digital Taxation and Permanent Establishment: Treaty Benefits, Choice of Entity, and the OECD
Taxation of Services Performed Inside and Outside the U.S.
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This webinar will explore the taxation of digital commerce inside and outside the U.S. Our panel of international tax experts will explain how treaty benefits can operate to mitigate taxation and the evolution of the historical definition of permanent establishment (PE).
- Permanent establishment: background
- Choice of entity
- Digital taxation
- Examples using specific treaties
- OECD developments
The panel will cover these and other critical issues:
- How to utilize treaty benefits to mitigate or avoid taxation
- How are digital services taxed internationally?
- When does a relationship with an agent constitute a PE?
- How are nonresidents who are not eligible for, or who do not utilize, treaty benefits taxed in the U.S?
- How do specific countries define PE?
Pamela A. Fuller, JD, LLM
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide... | Read More
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide range of clients–including private and public companies, joint ventures, funds, high-net-worth individuals, C-Suite executives, and government entities–on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. Ms. Fuller advises clients on both purely domestic transactions and transnational ones, helping both U.S.-based companies and foreign companies (and their executives) achieve the best possible results from a tax and business perspective. Ms. Fuller is Chair of the ABA’s Tax Section’s Tax Policy Committee, and also Co-Chair of the International Tax Committee of the ABA’s worldwide International Law Section. She frequently speaks at law conferences, and publishes papers on international tax topics in peer-reviewed law journals.Close
Patrick J. McCormick, J.D., LL.M.
Culhane Meadows Haughian & Walsh
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close
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