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1. What is the IRS Publication that deals with U.S. tax Treaties?
2. Does the US have treaties with China, Japan and Chile?
3. What is a permanent establishment? Is it the same for all of the three afore mentioned countries?
b. If a US person represents a US business in the afore mentioned countries, does this create a permanent establishment in the US employer? Assume that the US person is not acting as an independent agent.
c. What are the consequences of a U.S. business establishing a permanent establishment in the afore mentioned countries?
4. Locate the treaties with China and Japan. Find the provision governing entertainers and sportsmen. For both China and Japan, how much can a resident of each country earn before being subject to taxation in the other country?
5. Go to the provision governing students for both China and Japan. Consider a student from China and Japan studying in the US. The Chinese or Japanese student receives a scholarship from a Chinese or Japanese charity to study in the US.
a. Is the student subject to US income tax on the money received from either country?
b. Is there a time limit on this provision? If so, how long is it?
c. If the student is a part-time student in the US, how much can the Chinese and Japanese student earn before being subject to US tax?
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