"Agents as Permanent Establishments: Avoiding the US Income Tax for Foreign Busi-nesses"
|
[1996] Taxes The Tax Magazine 101
|
Taxes: The Tax Magazine
|
United States
|
circa 1996
|
HeinOnline
|
|
1
|
"The Agency Element of Per-manent Establishment: The OECD Commentaries from the Civil Law View (Part One)"
|
(1993) 9 Intertax International Tax Review 396
|
Intertax. International Tax Review
|
|
circa 1993
|
|
|
1
|
"Australia Tribunal Considers Independent Agent Exception in Treaty's Permanent Establishment Definition"
|
[1993] Tax Notes International 234
|
Tax Notes International
|
United States
|
circa 1993
|
|
|
1
|
"The Agency Element of Permanent Establishment: The OECD Commentaries from the Civil Law View (Part Two)"
|
(1993) 10 Intertax International Tax Review 488
|
Intertax. International Tax Review
|
|
circa 1993
|
|
|
1
|
"Agents as Permanent Establishments Under the OECD Model Tax Convention"
|
(1993) 5 British Tax Review 341
|
British Tax Review
|
United Kingdom
|
circa 1993
|
Westlaw
|
|
1
|
"Supervisory Activities as Permanent Establishments: The Australia/Japan Treaty"
|
(1993) 3 Revenue Law Journal 48
|
Revenue Law Journal
|
Australia
|
circa 1993
|
Informit
|
|
1
|
"Tax Treaties, the One-Shot Deal and Capital Gains: Thiel v FCT"
|
(1990) 2 Tax Notes International 1137
|
Tax Notes International
|
United States
|
circa 1990
|
|
|
1
|
"The Treatment of Trusts Under the OECD Model Convention - II"
|
(1989) 3 British Tax Review 65
|
British Tax Review
|
United Kingdom
|
circa 1989
|
Westlaw
|
|
1
|
"The Treatment of Trusts Under the OECD Model Convention - I"
|
(1989) 2 British Tax Review 41
|
British Tax Review
|
United Kingdom
|
circa 1989
|
Westlaw
|
|
1
|
"The Case Against Fixed Base"
|
(1988) 10 Intertax International Tax Review 282
|
Intertax. International Tax Review
|
|
circa 1988
|
|
|
1
|
"Permanent Establishments in the United States"
|
(1976) 29 Tax Lawyer 277
|
Tax Lawyer
|
United States
|
circa 1976
|
HeinOnline
|
|
1
|
Fleming v London Produce Co Ltd
|
(1968) 2 All ER 975
|
|
United Kingdom
|
circa 1968
|
LexisNexis
|
|
4
|
Donroy Ltd v US
|
(1962) 301 F 2
|
|
|
circa 1962
|
|
|
1
|
MNR v Sunbeam Corporation (Canada) Ltd
|
[1961] CTC 45
|
|
Canada
|
circa 1961
|
|
|
1
|
Firestone Tyre Co Ltd v Lewellin
|
[1957] 1 All ER 561
|
|
United Kingdom
|
circa 1957
|
LexisNexis
|
|
6
|
Consolidated Premium Iron Ores Ltd
|
(1957) 57 DTC 1146
|
|
Canada
|
circa 1957
|
|
|
3
|
104 Tax Cas 535
|
104 Tax Cas 535
|
|
United Kingdom
|
circa 1957
|
|
|
1
|
No 630 v MNR
|
59 DTC 300
|
|
Canada
|
circa 1957
|
|
|
2
|
7 CTBR (NS) 652
|
7 CTBR (NS) 652
|
|
Australia
|
circa 1957
|
|
|
1
|
5 CTBR (NS) 656
|
5 CTBR (NS) 656
|
|
Australia
|
circa 1957
|
|
|
1
|
1 CB 55
|
1 CB 55
|
|
|
circa 1957
|
|
|
1
|