United States Tax Considerations for Non-Resident Business Enterprises

Historically, the United States has imposed a tax on a non-resident, either on income effectively connected to the non-resident's United States trade or business or (where a tax treaty applies) business profits attributable to a non-resident's United States permanent establishment. This program will provide background on the United States' historical approach to taxing foreign-based businesses with domestic trade or business activities, looking at the standards for finding a trade or business/permanent establishment. The evolution of the standard will also be covered, emphasizing the continuing adaptation of the norm for a digitized economy.

Learning Objectives:

1. Review the history of the United States' taxation of foreign-based businesses with domestic trade or business activities

2. Identify the standards for finding a trade or business/permanent establishment

3. Explore the adaptation of standards for finding a trade or business/permanent establishment to the digitized economy