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Corporate - Corporate residence
Last reviewed - 15 August 2025A corporation organised or created in the United States under the law of the United States or of any state is a domestic corporation. A domestic corporation is a resident corporation even though it does no business or owns no property in the United States.
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A PE generally is defined as a fixed place of business or a dependent agent that a non-US company has in the United States.
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US Tax Leader, PwC US
US Tax Knowledge Management Leader, PwC US
Nikole Flax on IRS' guidance flow, other challenges (8:14)
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Nikole Flax on IRS' guidance flow, other challenges (8:14)
Nikole Flax discusses moving pieces in Washington impacting IRS guidance, including filling key political seats and competing pressures related to CAMT and the economic substance doctrine.