Lee has written two of the standard works on corporate and private wealth taxation
Fundamentals of Permanent Establishments (Second Edition)
The permanent establishment (PE) concept is a threshold issue which must be confronted and addressed by virtually every enterprise seeking to conduct trading activities in one or more countries other than its home country. Whether or not an enterprise has a ‘permanent establishment’ in a country defines whether its trading income can be taxed or is exempt under a network of over 1,000 bilateral income tax treaties and some local laws. Today, the interaction of rapidly changing rules, increased enforcement, and evolving business operations creates a challenging environment for tax directors of global businesses who must understand and manage their company’s PE risks.
This updated and expanded second edition of a concise guide that has been a key reference for decades – formerly titled Permanent Establishments: A Planning Primer – provides lucid insight into business structuring and the related tax considerations. Completely updated and expanded, it remains the only practical introductory book on PE available. It covers all important aspects of fixed place of business and dependent agency types of permanent establishment, as well as the exceptions for independent agents, permitted ancillary activities, and parent–subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions.
Notable features of the new edition include the following:
- entirely new chapters on e-commerce, supply chain and contract manufacturing structures, and service PEs;
- thorough updating of model treaty changes and PE rulings globally; and
- impact of new developments in mineral extraction, real estate leasing, and construction management.
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This unique book is a concise, complete tax-planning manual for high net worth individuals of the UK, the US, or any other nationality who have UK or US residence, assets, or family members. The second edition is fully revised and updated to include all major legislative changes that a tax professional is likely to require when advising clients exposed to both UK and US taxation, providing: a quick reference summary of the UK and US rules applicable to clients, a comprehensive summary of available unilateral and treaty planning techniques to avoid US estate tax or UK inheritance tax for clients who are non-domiciliaries of the UK or US, optimal income and gains tax planning for foreign trusts with UK or US beneficiaries, and integrated UK and US tax planning solutions for clients exposed to both UK and US tax. Amazon.com
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