Rocco Femia and Bob Kirschenbaum will speak on "Permanent Establishments: Treaty v. Non-Treaty Issues."

Topics will include: (1) the Context and Overview of U.S. and OECD standards (including practical advantages of PE status); (2) a Perspective from India (including reservations on OECD Commentary, profits attribution to a PE, and dispute resolution channels); and (3) Current Developments (including recent developments in Europe, profit attribution methodologies, PE risk minimization strategies, and accounting for PE uncertainty).