Business Profits Taxation under U.S. International Tax Treaties

Summary

This practice note discusses the taxation of business profits under U.S. international tax treaties, focusing on the critical role these treaties play in preventing double taxation and clarifying cross-border tax obligations. It explores the concept of permanent establishment (PE) and the classification of income, providing practitioners with the necessary insights to navigate international taxation challenges. The note is structured into sections covering the taxation of business profits, the impact of treaties, U.S. taxation in the absence of treaties, and a checklist for examining business profits taxation under U.S. international tax treaties.