Business Profits Taxations and the Importance of Tax Treaties

Explore 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. This practice note explores the concept of permanent establishment and the classification of income, providing practitioners with the necessary insights to navigate international taxation challenges.

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Related Content

• U.S. Income Tax Treaties Fundamentals
  Learn how tax treaties operate in transactions between U.S. and non-U.S. parties (also referred to as cross-border transactions). If you are advising clients on transactions involving non-U.S. jurisdictions, you should understand how tax treaties operate in order to successfully advise a client on how to minimize taxes in the relevant countries.

• Transfer Pricing Tax Fundamentals
  See how international taxation is impacted by transfer pricing issues. The transfer pricing rules determine how related parties price their transactions to determine how profits are distributed within a business' worldwide structure or organization. The rules are set forth in I.R.C. § 482 and the accompanying regulations in Treas. Reg. §§ 1.482-1 through -9. 

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  • International Taxation. President Trump issues a memorandum providing that the OECD Global Tax Deal no longer applies in the United States, with a stated goal of safeguarding sovereignty and competitiveness while combating extraterritorial, discriminatory taxes impacting U.S. businesses. The Organization for Economic Co-operation and Development (OECD) Global Tax Deal (Global Tax Deal); 90 Fed. Reg. 8483 (Jan. 30, 2025).
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