Under a U.S. treaty, what must a non-resident corporation create in the United States before it is subject to U.S. taxation on its business profits?

Question

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According to U.S. tax treaties, a non-resident corporation must establish a permanent establishment, which is defined as a fixed place of business, before it is subject to U.S. taxation on its business profits. The permanent establishment may include a branch, office, factory, workshop, or other physical presence in the United States. Simply having an asset, an employee, or engaging in U.S. trade or business may not necessarily trigger taxation without a permanent establishment.

Under a US