Write an essay explaining the meaning of a permanent establishment and business profits under the three models. Think of your audience as someone who does not know anything about this topic. Explain how a business will be taxed under the description of a “permanent establishment” and give examples. Then do the same thing for business profits. The paper should be set up as a research paper.
The three models are
Technical explanations to the U.S. Model
Technical Explanations to the OECD Model
Technical Explanations to the U.N Model
Look at: CPA journal March 2011 and an article about Dr J Zarb, helpful!
Also look at, IRS Website/List of countries with which the U.S. has signed a DTT
