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Tax Lawyer, Vol. 63, No. 2 CHANGES TO THE PERMANENT ESTABLISHMENT ARTICLE 285285“Songs of Innocence and Experience”:Changes to the Scope and Interpretation of the Permanent Establishment Article in U.S. Income Tax Treaties, 1950–2010J. ROSS MACDONALD*Pouring floods of rain . . .Won’t Mount Fuji wash awayTo a muddy lake?1I. IntroductionThe permanent establishment concept has been an integral element of U.S. income tax treaties since the first U.S. income tax treaty in 1932.2 Although the specific...