WEBINAR
Permanent Establishments in a Canada-U.S. Cross-Border Context
July 8, 2009 12:00–1:30 PM (EDT)
Presenters: David Kerzner and Vitaly Timokhov

Insight will be provided regarding domestic Canadian and U.S. tax rules that create reporting and tax liability in both countries arising from a PE. An overview of PE under Article V, including an explanation of the general rule, agency rule, PE exemptions, the new PE services rule under the Fifth Protocol as well as the interaction of PE rules with the new hybrid entity provisions of the Canada-US Treaty will be discussed. The presentation includes practice tips on managing PE risk in Canada and the U.S.
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