Deck 9: International Tax Services

Question 1

Explain how the passage of a state tax bill is similar to the passage of a federal law.

Answer 1

Federal tax law :
It applies to all the people in US whether they are citizens, residents or corporations situated there or anywhere else in the world. Thus, residents, citizens or corporations are taxable on their worldwide income regardless the fact, in which they are situated.
State tax law :
It is the law created by the state constitution which is effective within that particular state only. The significance of state law is different in different states which mean that people of one state can have more or less rights or responsibilities than other state.
The passage of federal tax law is similar to passage of state tax law in terms of the below mentioned points:
a) The law created by state constitution supervenes upon all other state laws, like the federal laws.
b) Both the federal tax law and state tax law are applicable to the citizens, residents and corporations in US.
c) State tax law cannot supervene upon the federal tax law in any case.

Question 2

What are the major models for developing international taxing systems

Answer 2

International taxation: As per U.S. Department of state, there are 195 countries in the world recognized today and generally each has its specific tax rules and guidelines.
As result, there are a number of universal businesses in the world, and most of the businesses are unfamiliar with the tax laws of different countries, therefore the global businesses must have to move through a web of tax laws that are not familiar with most of the tax laws.
The purpose of the international tax rules of each country should be to confirm that, the taxing system interact powerfully and to prevent, to the amount possible double taxation of income. At such a time, every country desires to promote worldwide trade or business but not destroy its local tax base for making revenues.
For developing the international taxing systems, the most common model includes, 'worldwide model' and the 'territorial model'.
As per worldwide model, a country imposes taxes on its taxable residents on the basis of their universal income, irrespective of its source. It would contain income earned in other countries as well as income earned by overseas subsidiaries even profits of such subsidiaries not distributed to the parent company.
All the expenses which are incurred for earning those overseas incomes are deductible promptly. As because the overseas earned income are also taxed by the country in which transactions taken place, therefore the native country allow a foreign tax credit for the tax paid to other countries. Generally a pure worldwide model of taxation is not used by most of the countries.
As per territorial model, a country imposes taxes only on the income which is earned within its own territorial boundaries. In this, income earned by a business outside its native country or income earned by overseas subsidiaries would not be taxed even if the profits of subsidiaries distributed to the parent company.
In this, the deductions related with the foreign income are not allowed as because the foreign income is taxable in such foreign country in which such income earned. Moreover, foreign tax credit also not allowed.

Question 3

Locate the Website for the MTC.
a. Define the three levels of membership in the MTC.
b. Provide a brief summary of one of the latest articles in the Multistate Tax Commission Review. (Hint: Publications are found in Resources.)
c. What is the Nexus Program When was it founded
d. How does a taxpayer initiate joint audits
e. The MTC provides a link to the Federation of Tax Administrators (FTA). What is the title and date of the most recent FTA meeting

Answer 3

NO ANSWER

Question 4

Use the BNA Tax and Accounting Center States tab for the following questions:
a. What is the title of State Portfolio 1550 How many worksheets are included in this portfolio
b. Which portfolio explains the state tax effects of the QSSS election for S corporations
c. How many basic forms of drop-shipment transactions are there In which portfolio did you find your answer

Question 5

Tom and Verna are going to combine their fishing businesses to become more profitable. Tom currently lives in Mississippi, and Verna lives in Louisiana. They would prefer to set up the business as an S corporation, but only if it will not be subject to state taxation. Since Verna and Tom live within 20 miles of each other, they do not have a preference as to the state of incorporation. Does it make a tax difference which state they choose

Question 6

Melkry, an Ohio corporation, provides tugboat services on the Great Lakes to vessels weighing at least 800 tons. Each of Melkry's tugboats weighs approximately 100 tons. Michigan has assessed use tax on repair materials, fuel, and capital assets purchased by Melkry for its operations. Is Melkry subject to the use tax

Question 7

VanDelay, a citizen of the United States but a resident of Dulcinea, is an important sculptor. This year, he came to the United States to appear at an exhibition of his work in San Francisco. The United States has no tax treaty with Dulcinea. Does the $250,000 that VanDelay netted from the show qualify for the I.R.C. § 911 earned-income exclusion

Question 8

As mentioned previously, Anh really enjoyed the lifestyle in southern California. After living in student housing her first year, she immediately moved off campus into a nearby apartment. Over time, Anh started to grow quite comfortable in the United States. Her English improved a great deal, she managed to get a California driver's license, and she even bought a used car that she registered in California so she could drive back and forth to school (and perhaps occasionally to the beach). She became very good friends with a number of her classmates and from time to time even dated one or two. At the end of 2013, she had been dating one student for approximately four months; the relationship was showing signs of becoming serious but it was still too early to tell. Although Anh missed her friends and family back in Vietnam terribly, she was beginning to think maybe she could stay in the United States after she finished her degree, but only if she could find a firm to sponsor her work visa. Prepare an addendum to the previous memo that discusses the California residency treatment of Anh in 2013 and determine whether her income is taxable in California.

Question 9

When would federal rulings be pertinent to state tax issues

Question 10

What is the worldwide model of international taxation Explain whether a corporation with only domestic income or a company with foreign income would pay more taxes under this model.

Question 11

Use the Checkpoint State Local Practice Area to locate the Bacchus Imports Ltd. v. Herbert H. Dias case using the Federal Cases in the State Taxes option.
a. What is the citation for the case, and what court heard this case
b. Which clauses of the U.S. Constitution did Bacchus allege were violated
c. Must the names of the plaintiff and defendant in the case be entered to find the case Explain your response.
d. Read this case. Perform a keyword search to locate the case without using the plaintiff or defendant names. If necessary, use the Search Within Results feature. What keywords did you use for the general search and (if necessary) for your follow-up search

Question 12

Locate state tax newsletters to answer the following questions:
a. What is the title of the most recent article in Tax Analysts' State Tax Today that discusses royalty trusts
b. What is the most recent article in BNA's Tax Management Weekly State Tax Reporter that discusses the streamlining of sales taxes
c. What is the title of the most recent article in CCH's State Tax Day on gasoline taxes
d. What is the title of the most recent article in CCH's State Tax Review that discusses sales tax obligations of advertising agencies
e. What is the subject of one of the most recent articles in RIA's State Local Taxes Weekly newsletter

Question 13

New City, California, charged Rick a real estate transfer tax when his property was relinquished to the Federal Housing Administration (FHA) in its capacity as his loan guarantor. The amount charged was the same as the amount Rick was required to pay the county. Can Rick be required to pay this tax, or should the FHA pay it

Question 14

EmiLu Corporation is a private delivery company that hires independent contractors with their own trucks to deliver car parts to various auto repair shops in Pennsylvania. EmiLu contracts with the manufacturers of the car parts to make the deliveries, and then it hires the drivers in Pennsylvania to deliver the parts. EmiLu has no property, employees, or customers in Pennsylvania. EmiLu is incorporated in Delaware, where all the car-part-manufacturing customers are located. Is EmiLu subject to the corporate franchise tax in Pennsylvania

Question 15

State University invites Dr. Byko, a Russian citizen, to become a member of the faculty for a three-year period to work on a large grant the university obtained from the National Aeronautics and Space Administration (NASA). Dr. Byko accepts the invitation and enters the United States on a J-1 visa. His university pay is entirely funded by the NASA grant. Based on the Russian treaty, Dr. Byko thinks his income is exempt because it is from a grant. Determine whether Dr. Byko is correct.

Question 16

As a result of the income she generated from her on-campus job, Anh found herself with a small amount of disposable income. In early 2013, she took $1,000 of her disposable income and purchased shares in Jefferson Realty Trust, a real estate investment trust (REIT) for which shares are traded on a major U.S. stock exchange. In late 2013, she realized she needed to purchase some holiday presents for her friends, including her previously mentioned significant other, and sold all her shares in the REIT for a gain of almost $800. She sold the REIT prior to the trust paying any dividends. What is the U.S. treatment of Anh's gain on the sale of the REIT shares

Question 17

List some of the more common modifications to federal income to arrive at state income.

Question 18

What is the territorial model of international taxation Under this model, what rate of tax does a native corporation pay on its foreign income

Question 19

Use the Checkpoint State Local Practice Area to answer the following questions:
a. Select the state in which the university you are attending is located and go to the next screen.
b. What corporate items are provided in the tax-type list Is there a tax on intangibles, mortgages, or stock transfers
c. Select Florida (or Washington if your university is in Florida) as the state of interest and go to the next screen. What tax types are different between the two states
d. Select the state in which the university you are attending is located. What is the rate of tax per pack of cigarettes Compare your state's rate to that of Washington state. In what order are the Tax Types listed In what order are the Document Types listed

Question 20

Find an article in the Journal of Multistate Taxation and Incentives on each of the following topics. Provide the authors, article title, and date published.
a. The ad valorem property taxes on a baseball stadium.
b. Most recent economic incentives provided to the film industry.
c. Credits and exemptions used by Mississippi to promote the development of broadband technology.
d. The most recent article on the dividends-received deduction.

Question 21

TimberCut Corporation transferred all the rights to timber growing on its land located in Spokane County, Washington, to its wholly owned subsidiary, PineCo. The Department of Revenue has imposed a real estate excise tax on TimberCut because PineCo. transferred $1 million cash to TimberCut. Is TimberCut's transfer a sale of timber land subject to the taxes imposed

Question 22

Earl and Kathy live on the "Big Island" of Hawaii in the town of Captain Cook. Because the altitude is high, they grow coffee plants on their property. Most of their neighbors grow coffee as well. Earl and Kathy collect the coffee from their property and that of their neighbors, and then they dry the coffee in a special building they have constructed on their land. Does this activity affect their qualification for the home exemption for Hawaii property taxes

Question 23

Haruo, a resident alien, obtained a divorce in the United States from his wife, Wakana, two years ago. Last July, Wakana returned to Japan, but Haruo remained in the United States. For all of the current year, Haruo paid alimony to Wakana in the amount of $10,000 per month. Does Wakana have income subject to U.S. taxation or withholding

Question 24

Describe the differences between allocation and apportionment.

Question 25

Describe whether the United States uses a worldwide or territorial model.

Question 26

Use the Checkpoint State Local Practice Area to answer the following questions:
a. For the state of your choice, compare the listing of documents available under the option Select Document Types in the Search States (SALT) with the list for the same state in the TOC.
b. Using the Index in the TOC for the State Reporter for Illinois, what are the listings for the letter "H" under the "stamp" heading
c. In the Hawaii TOC, what is the fee for filing articles of incorporation for an LLC
d. In the Miscellaneous Multistate Materials TOC, what are the U.S. statute titles listed for Federal Laws on State Taxation

Question 27

Use the Journal of State Taxation to answer the following questions:
a. What is the title of the most recent article on Web-related activities and potential nexus problems
b. What are the volume and number of the most current issue What is the lead article
c. Who is the current editor of the journal Is anyone on the advisory board from the university you attend If yes, list the name(s).
d. Who is the author of the article titled "A Deal's a Deal: Why State Cannot Unilaterally Amend the Multistate Tax Compact" What are the year, volume, and issue number in which the article appears

Question 28

WaterWorks Corporation has decided to sell off one of its amusement parks located in Texas. Several businesses have been identified as possible buyers. It is unlikely that one of these businesses by itself will purchase all the assets of the amusement park, but WaterWorks is confident that it can sell all the assets to various parties within a six-month period. Is this sale subject to Texas sales tax

Question 29

Chuck Taylor owns a fish-processing plant in Alaska. Some of the processing chemicals and fish remains could be considered hazardous wastes. What possible state and local taxes does Chuck need to be concerned about when disposing of these materials

Question 30

Rainbow Corporation has a contract with the National Science Foundation to conduct research in Antarctica. Harriet, a U.S. employee of Rainbow, spent all of last year and part of this year working at McMurdo Station on Ross Island, Antarctica. When filing her return for last year, Harriet excluded her income from the contract, based on the fact that she worked outside of the United States. Her income was not in excess of the excludible ceiling. Is Harriet correct in her treatment of last year's income

Question 31

What are the purposes of the MTC

Question 32

What are the general rules for sourcing income

Question 33

Use the CCH IntelliConnect State Tax to answer the following questions regarding the state in which the university you are attending is located:
a. What is the title of the most recent article in State Tax Day related to this state
b. What is the most recent court case in the news for this state
c. In the State Tax Reporters, perform a keyword search using the term "escheat." What does this term mean and to what does it apply In which paragraph did you find the answer
d. Using the Topical Index for Multistate Property Tax Guide , perform a keyword search for "damaged property." In which paragraph are the rules for damaged property covered

Question 34

Use Internet sites to answer the following questions:
a. Provide the links to three News Topics sites provided by Tax Sites for states ( www.taxsites.com ).
b. Visit three national associations that are concerned with state tax issues. Provide the Websites' URLs.
c. Visit the Website of your state's agency responsible for taxation (the Department of Revenue, for many states). Provide the URL for this agency. For California, provide both agencies' URLs.
d. Select an adjacent state and give a summary of one of its taxes. (You could use Alaska and Hawaii as a pair.)

Question 35

A tribal nation in Kansas is considering building a gas station to accommodate people traveling through their reservation. Before undergoing the considerable expense for construction, the tribe members want to know whether the fuel sold will be subject to state fuel taxes. This will make a difference in the profitability of the project. Is gasoline sold on a federally recognized reservation subject to the fuel tax imposed by Kansas

Question 36

Jefferson W. Clinton is a resident of Arkansas but has not filed an income tax return nor paid any tax liabilities for the years 2004 to 2008. Does Arkansas currently have a tax amnesty program that would relieve Jefferson of some of the penalties and interest on his unpaid liabilities

Question 37

Moonsoo, a Republic of Korea citizen, went to San Diego, California, on a vacation. Because he liked San Diego, Moonsoo purchased five acres of land, on which he wants to build luxury condominiums. He also bought the majority interest in a construction corporation that specializes in condominium construction. Moonsoo could not get the zoning clearance to build the condominiums, so he sold both the land and his stock in the construction corporation. Is Moonsoo taxed in the United States on his gains from these sales

Question 38

What is included in the Checkpoint StateNet

Question 39

What are the general rules for assigning expenses to certain sources of income

Question 40

Use the CCH IntelliConnect State Tax to answer the following questions:
a. Does Hawaii allow estates a personal exemption If yes, what is the amount, and which state statute allows such amount
b. Using the Browse Window, drill down into any state with a corporate income tax and find the explanation for the sales factor under allocation and apportionment. Then use the Related Information All States button to show the results for all states. Now clear that search and select all the state tax reporters and do a keyword search for sales-factor apportionment. Explain why one search method might be preferable to the other.
c. Use the Thesaurus (under advanced search) and find the synonyms for the term "devise."

Question 41

Use the BNA Tax and Accounting Center International tab to answer the following questions:
a. Which countries are included in Tax Planning International Asia-Pacific
b. Using the Tax Treaties Comparison Tool, prepare a comparison chart of the U.S.-Austria Treaty and the U.S.-Canada Treaty. How do the definitions of permanent establishment differ
c. Does Switzerland have a tax treaty with China Does Switzerland have a treaty with Ghana
d. In which language does BNA have the Switzerland-Ghana treaty

Question 42

A town in Vermont wants to charge property tax on a lot and building used by a not-for-profit organization as its administrative office. To be exempt from property taxes, the property must have the following characteristics:
• Be dedicated to public use.
• Have its primary use directly benefit a class of persons who are part of the public.
• Be owned and operated on a not-for-profit basis.
Does administrative use of the building meet the definition for the exemption

Question 43

Chicago Tool and Die Corporation (CTDC) recently purchased an aircraft for the top executives to use for customer visits, transporting employees from one location to another, and matters relating to acquisitions and lawsuits. Upon purchase, no Illinois sales tax was charged, as the seller did not have Illinois sales-tax nexus. The aircraft was hangared in Ohio but made numerous trips (more than 200) in and out of Illinois airports. In the year of purchase, was CTDC liable for Illinois use tax

Question 44

Ireland imposes a tax on the net market value (less certain deductions) of the taxable assets of those individuals residing in Ireland. Although she is a U.S. citizen, Katherine has been residing in Ireland for the past five years. She owns property located in Ireland and property located in the United States. Much of her property consists of stocks and bonds, but she also has large holdings of land in both countries. Does this Irish tax qualify for the foreign tax credit and/or as a deduction for U.S. tax purposes

Question 45

What is the function of the CompareIt feature in Checkpoint

Question 46

How does transfer pricing complicate international tax matters for large multinational companies

Question 47

Use the CCH IntelliConnect State Tax to answer the following questions:
a. Did Alaska ever have a personal income tax If yes, in what year did Alaska repeal the tax
b. Use the Multistate Quick Answer Charts to determine the diesel fuel tax for the state in which your university is located. Which state has the highest diesel fuel rate
c. What, if any, tax legislation was enacted by the state in which your university is located this week How about since the beginning of the year
d. Determine which states have Jai Alai taxes.

Question 48

Use the BNA Tax and Accounting Center International tab to answer the following questions:
a. What is the proper citation for the most recent article in the European Tax Service on the United Kingdom's VAT
b. Who are the authors of the Tax Management International Forum for the Netherlands
c. Use the Quick Search option to determine how many articles Bert Mesdom has written.

Question 49

Iowa imposes a tax on the operation of slot machines. The rate is graduated based on slot machine revenues. Can Iowa charge a higher maximum rate to racetrack owners than it does to riverboat owners without violating the equal protection clause of the U.S. Constitution

Question 50

James Bulger works at a sandwich shop in Ames, Iowa. During his coffee break each afternoon, he enjoys a candy bar that his employer sells to him at an employee discount. Candy bars are not exempt (as food) from sales tax in Iowa, and his employer charges him sales tax on the purchase. Recently, James noticed that his employer was charging him sales tax on the retail sales price ($1), not the employee discount price ($.80) that James actually pays. What is the proper amount to calculate the sales tax on, the actual (reduced) price or the retail price

Question 51

Paul Thomas and Karen Jackson are both in the U.S. Armed Forces and each receives combat zone pay. Karen is a commissioned officer, whereas Paul is enlisted personnel. How is each taxed on the combat zone pay How does Paul treat his combat zone pay when computing his earned income tax credit

Question 52

Why are taxpayers emphasizing multijurisdictional tax planning

Question 53

Compare the Multiple Sources search with the State and Local Taxes initial search option in Checkpoint.

Question 54

Describe the standard for transfer pricing in most countries.

Question 55

Use Lexis Tax Center to answer the following questions:
a. Use the Florida Practice Insights to determine whether having a third party sell your out-of-state corporation's gift cards in its Florida stores is likely to create nexus.
b. What section of the Florida code covers the issue in the previous question
c. Are there any cases related to this issue (hint: use the Case Notes in the Practitioner's Toolbox in the upper right-hand corner of the Florida Statute document)

Question 56

Use the BNA Tax and Accounting Center International tab to answer the following questions:
a. What collections are available under the foreign income portfolios heading when using a Guided Search
b. What is the lead report in the most recent International Tax Monitor
c. What countries are included in Middle East/Africa in the Global Tax Guide collection

Question 57

The Pluto Corporation has been mining ore in Oklahoma for many years. A new mine just developed is producing ore that contains uranium. Pluto would like to know the rate of the severance tax on mined uranium, and upon what base the tax is assessed.

Question 58

Sal Bermuda recently invested in a new flavored water that he is bottling and selling at street vendor carts throughout the city of Chicago. Sal's water is flavored with natural ingredients and just a touch of sweetener. Some of Sal's customers have been explaining how happy they are that Sal has not been charging them a $.05 bottled-water tax. Sal has never heard of such a tax and is wondering if there are any other taxes aimed specifically at his bottled water product.

Question 59

Three international students are paid $1,000 per month to be teaching assistants in their university's Department of Accounting. The students from India and China have been in the United States for six years, and the student from Spain arrived one year ago. How is each of the students taxed in the United States for the current year

Question 60

Why is state and local tax planning becoming more important

Question 61

Discuss the citation search capabilities in the Checkpoint state and local tax practice area.

Question 62

Describe the functions of the OECD.

Question 63

Use Lexis Tax center to answer the following questions:
a. Which chapter of Bender ' s State Taxation: Principles and Practice covers sales and use tax nexus
b. Using the information found above, what are the names of the two cases that cover the basis of the economic-nexus argument
c. Which well-known retailer and which U.S. state were at the center of the Geoffrey case

Question 64

Use the BNA Tax and Accounting Center International tab to answer the following questions:

A) What is the name of a limited liability company in Colombia
B) What section of the French tax code provides the general rules for transfer pricing
C) Use the Advanced Search option to locate a 2012 article discussing China continuing to offer VAT refunds for the animation industry. Provide the source of the article.

Question 65

The Peppermint Partnership operates a successful candy business. It is considering taking the partnership public and becoming a master limited partnership. If it does so, will it be subject to the corporate franchise tax in New York, where its headquarters and operating plant are located

Question 66

Apache and Alice Swearingen moved to Minnesota in 2009. Apache retired in early 2012, and the Swearingens purchased a motor home, started traveling extensively, and put their Minnesota home up for sale. Due to lack of interest, however, they took their home off the market late in the year. In 2013, they spent approximately 15 days in South Dakota. While there, they registered a mailbox address with a private company, and using that address obtained South Dakota driver's licenses, opened a bank account, registered to vote, and registered their vehicles in South Dakota. In March 2013, they relisted their Minnesota home for sale. In April 2013, they returned to Minnesota from their road trip to South Dakota (and other states as well), and in June 2013 they finally sold the Minnesota home. They spent the rest of 2013 traveling the country in their motor home. Are the Swearingens required to file a Minnesota resident income tax return for 2013

Question 67

A group of Russian tourists spent a week in Las Vegas. Kolzak, one of the tourists, was very lucky at the roulette table and won $50,000. Is Kolzak subject to U.S. income tax, and is the casino required to withhold taxes on her winnings

Question 68

Describe the different constitutionality challenges with regard to federal and state taxes.

Question 69

How are specific states' tax laws selected using CCH IntelliConnect

Question 70

If a provision of the Internal Revenue Code and a tax treaty are in conflict, which rule prevails

Question 71

Using the LexisNexis Academic Sources option to do the following:
a. Find the source that contains the San Jose Mercury News newspaper and perform a keyword search for apple and "Dutch sandwich" with the source identified. What is the title of an article, published in the San Jose Mercury News in 2012, that addresses a Dutch sandwich tax issue
b. What sources are available for the state of Delaware in the Taxation area of law
c. What are the title and author of the most recent article in the Florida Tax Review with these three separate keyword terms: property, tax, and abatement Did you use a natural-language or terms and connector search

Question 72

Use the International Tab of LexisNexis Tax Center to answer the following questions:
a. According to Tax Havens of the World, who granted an exemption on taxes to the Cayman Islands and why
b. Who is the author of International Estate Planning
c. What is the title of Chapter 8 of the Foreign Tax Trade Briefs for Iraq
d. What is the maximum number of sources that can be searched at one time

Question 73

Rodney has been in the South Carolina National Guard for the past 20 years. This is his last year as an active member. When Rodney turns 65 in August of this year, he will begin collecting Social Security benefits and Guard retirement pay. His employer laid him off in January, and Rodney qualified for unemployment compensation. Rodney received severance pay of $50,000 when terminated by his employer. Which of these amounts are taxable to Rodney in South Carolina

Question 74

Evgenia is a resident of California. She recently purchased two computers from an online retailer that did not charge California sales tax. The retailer happened to be offering a steep discount if two computers were purchased in a single transaction. She gave one of the computers to her sister (also a California resident) for her birthday a few days after the computers arrived. Because Evgenia already had a fully functional computer, she stored the other computer for the next 18 months before finally upgrading to a new one. Is Evgenia responsible for California use tax for one, both, or neither computer, and when is the use tax due

Question 75

Which of the following payments by International Partners Inc., a Montana corporation, qualifies for the foreign-tax credit
a. Income tax paid to Germany, covered by an existing treaty.
b. Income tax paid to Adagio, with which the United States has no income tax treaty.
c. Value-added tax paid to Largetto, with which the United States has no income tax treaty.
d. Oil-extraction tax paid to Tedesco, with which the United States has no income tax treaty.
e. Transportation tax paid to Santa Lucia, with which the United States has no income tax treaty. The tax is reduced dollar for dollar when International provides consulting services in designing Santa Lucia's new bullet train system. This year, International incurred $1 million in taxes, but it earned a $600,000 reduction for its services.

Question 76

Discuss the supremacy provision in the U.S. Constitution.

Question 77

Describe some of the multistate sources available in IntelliConnect.

Question 78

Describe the two primary areas of international tax research.

Question 79

Use LexisNexis Academic Search option, Legal to answer the following questions:
a. Locate the following court case: T. C. Memo 1986-512. What is its citation, what court heard it, and when was it decided
b. Apply the Shepard's Citator to the above case. How many citing decisions are there for this case How many headnotes
c. Should the finding in this case be relied upon

Question 80

Use the International Tab of LexisNexis Tax Center to answer the following questions:
a. How many treatises and analytical materials sources are found for a search of William H. Byrnes
b. Which countries does Bhutan have tax treaties with
c. How many treaty documents cover the Bhutanese tax treaties
d. In which article of the 2006 U.S. Model Income Tax Treaty is permanent establishment discussed