Question: ( Permanent Establishments ( PE ) ) A U . S . manufacturer of furniture is considering entering the Canadian market. The company will use

(Permanent Establishments (PE)) A U.S. manufacturer of furniture is considering entering the Canadian market. The company will use one of the following alternatives to expand into Canada: A. Direct sales to wholesalers by full-time salespeople who report to a sales office in each of three Canadian provinces. The sales offices will coordinate marketing and shipping of products from two warehouses located in Canada. However, formal approval of contracts will be administered in the U.S. head office. B. The sales offices described in Part A would be independent profit centres with regional credit managers. The two warehouses from which orders are filled will be near the sales offices. C. Company online sales would be expanded to include shipping to Canada. Required: For each market expansion alternative, determine whether or not the U.S. manufacturer will be considered to have a PE in Canada. Justify your conclusion and identify any other information required in support of your position.

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