Note: Unless otherwise indicated, assume that the U.S. Model Income Tax Conventi

Question

Note: Unless otherwise indicated, assume that the U.S. Model Income Tax Convention of
November 15, 2006 (the “Model Treaty”).

USAco, a domestic corporation, decides to expand its sales in country F by hiring a salesperson there. Neither USAco nor the salesperson lease commercial office space in country F. The salesperson makes sales calls while performing the necessary administrative paperwork in her office at her home in F. Under the Model Treaty:

USAco is subject to tax in country F because the salesperson's office constitutes a permanent establishment.

USAco is not subject to tax in country F because the salesperson's office does not constitute a permanent establishment.

USAco is not subject to tax in country F because USAco is not engaged in a trade or business.

None of the above.

USAco is subject to tax in country F because the salesperson's office constitutes a permanent establishment.

USAco is not subject to tax in country F because the salesperson's office does not constitute a permanent establishment.

USAco is not subject to tax in country F because USAco is not engaged in a trade or business.

None of the above.

Explanation / Answer

Ans:USAco is subject to tax in country F because the salesperson's office constitutes a permanent establishment.

Reason: Because under the model treaty virtual transactions are covered from the country the revenue is generated and such country will deemed to be have permanetnt establishment.

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