id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-312	Morse, Susan C.	Startup Ltd.: Tax Planning and Initial Incorporation Location	2022	42	.pdf	application/pdf	18514	856	47	2013] Tax Planning and Initial Incorporation Location 327 parent’s chance of exposure to US tax because a treaty relationship increases the threshold for business taxation from the US statutory “effectively connected income” standard to the treaty-based “permanent establishment” standard.25 A treaty relationship also reduces withholding taxes that would apply, for example with respect to interest, dividend, and royalty payments from the US subsidiary to the parent.26 Because direct tax treaties between tax havens and the United States generally do not exist, any treaty planning for a US-parented structure with a tax-haven-incorporated parent would typically rely upon intermediate affiliates with excellent treaty networks.27 25. Yet the possibility of future change in US tax law does not appear to affect most startups’ incorporation location decisions.	cache/ftr-312.pdf	txt/ftr-312.txt