Friday, December 16 • 9:35 – 10:35 a.m. ET
Joan Arnold will chair a panel on Mobile (Global) Executives – Impact and Planning on Friday, December 16 at The George Washington University Law School: 33rd Annual Institute on Current Issues in International Taxation.
Through a case study, the panel will develop and explore a framework to analyze the company and individual tax issues that arise when an employee performs services for a corporation that is not located in the jurisdiction of the residence of the employee. They will address substantive tax issues and reporting and compliance and will consider a few means of self-help to manage the issues. Key issues include:
- Residency of the individual, taxing employment income, and compliance issues
- The existence of a PE as a result of the arrangements – will OECD change the answer?
- If a PE, what is profit attribution?
- Impact on operational tax analysis – DEMPE concerns
- Self-Help – using a local subsidiary, split payrolls, using a PEO, business-driven solutions. Is it really a help?