Canadian Tax Journal
Submitted by madnotes on May 22, 2008
- Category: Business
- Words: 506
- Pages: 3
- Views: 221
- Popularity Rank: 858
Canadian Tax Journal
2007 Vol. 55, No.2
The article analyzes issues of when a subsidiary may be a permanent establishment of its parent and, when it is a permanent establishment, what the further consequences are. To approach these issues, the author considered 2 possible scenarios – one where a Canadian parent corporation has a US subsidiary and the other where a US parent corporation has a Canadian subsidiary.
As for US subsidiaries, the assumption is that, if US operations are conducted through US subsidiaries, as opposed to branches, offices or other fixed places of business, there will be no tax on the foreign parent corporation . However, if the activities of a US subsidiary cause the...
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