TXX5766

Note: Unless otherwise indicated, assume that the U.S. Model Income Tax Convention of November 15, 2006 (the Model Treaty). USAco, a domestic corporation, decides to expand its sales in country F by hiring a salesperson there. Neither USAco nor the salesperson lease commercial office space in country F. The salesperson makes sales calls while performing the necessary administrative paperwork in her office at her home in F. Under the Model Treaty:

		USAco is subject to tax in country F because the salesperson's office constitutes a permanent establishment.
		USAco is not subject to tax in country F because the salesperson's office does not constitute a permanent establishment.
		USAco is not subject to tax in country F because USAco is not engaged in a trade or business.
		None of the above.