Permanent Establishments: A Planning Primer

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Kluwer Law and Taxation Publishers, Jan 1, 1993 - Law - 193 pages
This book is a comprehensive review of the tax treaty concept of a `permanent establishment' from its origins in early Prussian and British tax law to its present manifestation in over 1250 bilateral income tax treaties written by two of the leading authors on the subject. The book covers both Anglo Saxon and civil law precedent, The OECD and US model treaties used in developed country treaties and the differing approach of the UN model for developing countries.

The book exhanstively deals with all aspects of the `fixed place of business' and `dependent agency' permanent establishments and the exceptions for independent agents, permitted ancilliary activities and parent subsidiary relationships.

The text integrates conceptual analyses and technical discussion with relevant tax planning opportunities, appropriately highlighted or diagrammed. A number of valuable tax planning techniques are presented which have not been previously discussed in any literature.

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About the author (1993)

The son of Walter Huston, the well-known movie actor, John Huston directed numerous Hollywood films, including such classics as The Treasure of the Sierra Madre (1948), for which he won an Oscar as best director, and The Asphalt Jungle (1950). He wrote the screenplays for many of them, including the quintessential hard-boiled detective movie The Maltese Falcon (1941), which was also his directorial debut. Huston's protagonists are often either independent professionals whose tough exteriors hide a dedication to principle, like the detective in The Maltese Falcon, or losers whose obsession with a doomed quest leads to their destruction, like the three gold-seekers in The Treasure of the Sierra Madre. But, in his 46-year career, he would try his hand at almost everything, from the grand comedy of The African Queen (1952) to the shaggy dog tale Beat the Devil (1954), the offbeat western The Misfits (1961), the rather bloated epic The Bible (1966), and the medieval allegory, A Walk with Love and Death (1970). As he aged, his films seemed to get deeper and better, starting with The Man Who Would Be King (1975) and continuing with Wise Blood (1979) and Prizzi's Honor (1985). His final work, The Dead (1987), is an exquisite film adaptation of the short story by James Joyce.

Robert L. Williams is a lifelong resident of North Carolina. Together with co-writers Elizabeth W. Williams and Robert L. Williams III, he is the co-author of more than thirty books and has published numerous articles and photographs. His books include "100 Practically Perfect Places in the North Carolina Mountains, Gaston County", and "Explorer's Guide 50 Hikes in the Mountains of North Carolina".

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