The U.S. IRS has released two international practice units concerning permanent establishment status, including: Creation of a Permanent Establishment (PE) through the Activities of a Dependent Agent in the United States, which examines whether a U.K. company has a U.S. permanent establishment as a result of an agent concluding contracts on its behalf in the United States; and Preparatory and Auxiliary Treaty Exception to Permanent Establishment Status, which focuses on whether an activity has a preparatory or auxiliary character for purposes of determining whether there is a permanent establishment in the United States. Both practice units use the U.S.-U.K. Income...