Attached is a free pdf/ebook prepared by Alexander Weisser, covering permanent establishment, treaty characterization and transfer pricing.
These issues are becoming more important as we get closer to OECD Pillar One and Two blueprints, in addition to proposed UN Article 12B re: a new digital services tax focused on developing countries.
Alexander has provided advance permission for this informative inclusion:
Proposed Regulations were issued for cloud computing and digital transactions; this is an especially important area re: sourcing of income, definitions, etc. especially in light of France and others looking to implement a digital services tax.
Publication 5188 was revised re: FATCA data reporting.
OECD released Peer 2 review reports re: re: BEPS Action 14 (dispute resolution). Interestingly, some US treaties include a MAP provision, although not all are consistent with the minimum standard.
Click to access 2019G_003793-19Gbl_Report%20on%20recent%20US%20international%20tax%20developments%20-%2016%20Aug%202019.pdf