Comments on U.S.-Canada Fifth Protocol and OECD Services Draft

Abstract:     
This practitioner Article first summarizes the public comments of the New York State Bar Association, Ernst & Young, BDO Seidman, and the Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants regarding the Fifth Protocol to the U.S.-Canada tax treaty. It then selects and discusses six themes that appear in the eleven comments received by the OECD regarding its proposed extension of the concept of permanent establishment to certain service providers.

Number of Pages in PDF File: 5

Keywords: tax, tax treaty,United States,U.S.,Canada,protocol,Fifth Protocol,New York State Bar Association,NYSBA,Ernst & Young,E&Y,BDO Seidman,Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants,OECD,permanent establishment,PE,services,services draft

JEL Classification: K33, K34

Accepted Paper Series