The Tax Court of Canada issued a decision on 13 June 2022 in relation to the application of the service permanent establishment (PE) provisions of the 1980 tax treaty with the United States. The case involved Triskelion Projects International Inc., a U.S. company following a calendar tax year that provided consulting services in Canada in 2015 and 2016. The company provided services for a total of 194 days in 2015 and 54 days in 2016. A tax assessment was issued for the income earned in the 2016 tax year based on the existence of a service PE. Under the Canada-U.S....