FORco is a company incorporated in foreign country F. FORco sends a sales employee to...
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FORco is a company incorporated in foreign country F FORco sends a sales employee to meet with a US customer at the Miami airport to sign a purchase order that will bind FORco only if approved by FORcos management in country F The US customer signs the purchase order at the Miami airport and FORcos employee goes back home to country F the same day. Which of the following is true? a If country F has a treaty with the US FORco has a permanent establishment. b If country F does not have a treaty with the US FORco is conducting a trade or business in the US and may have effectively connected income ECI subject to US taxation. c If country F has a treaty with the US the transaction is considered a US trade or business, but the ECI may be subject to taxation at the lower treaty rates. d FORco has a permanent establishment independently of whether there is a treaty or not.
FORco is a company incorporated in foreign country F FORco sends a sales employee to meet with a US customer at the Miami airport to sign a purchase order that will bind FORco only if approved by FORcos management in country F The US customer signs the purchase order at the Miami airport and FORcos employee goes back home to country F the same day. Which of the following is true?
a If country F has a treaty with the US FORco has a permanent establishment.
b If country F does not have a treaty with the US FORco is conducting a trade or business in the US and may have effectively connected income ECI subject to US taxation.
c If country F has a treaty with the US the transaction is considered a US trade or business, but the ECI may be subject to taxation at the lower treaty rates.
d FORco has a permanent establishment independently of whether there is a treaty or not.
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