Thank you.There is a tax treaty in effect between the US and Canada. It states that as long as a Canadian corporation doesn't have a 'permanent establishment' in the US, its business profit will only be taxable in Canada and will not be taxable in the US.I assume this is similar to the issue of 'nexus'.The definition of "permanent establishment" is defined as:Permanent Establishment
1. For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of a resident of a Contracting State is wholly or partly carried on.
2. The term "permanent establishment" shall include especially:
(a) A place of management;
(b) A branch;
(c) An office;
(d) A factory;
(e) A workshop; and
(f) A mine, an oil or gas well, a quarry or any other place of extraction of natural resources.6. Not withstanding the provisions of paragraphs 1, 2, and 5, the term "permanent establishment" shall be deemed not to include a fixed place of business used solely for, or a person referred to in paragraph 5 engaged solely in, one or more of the following activities:
(a) The use of facilities for the purpose of storage, display or delivery of goods or merchandise belonging to the resident;
(b) The maintenance of a stock of goods or merchandise belonging to the resident for the purpose of storage, display or delivery;
(c) The maintenance of a stock of goods or merchandise belonging to the resident for the purpose of processing by another person;
(d) The purchase of goods or merchandise, or the collection
of information, for the resident; and
(e) Advertising, the supply of information, scientific research or similar activities which have a preparatory or auxiliary character, for the resident.So would using a 3rd-party warehouse in the USA constitute a permanent establishment?