This letter responds to the request in Notice 2017-28 for public comment on recommendations for items that should be included on the 2017-2018 Priority Guidance Plan. Recommendations in this letter cover various treaty abuse situations

In regard to "Options to address the broader direct tax policy challenges", I suggest that the Task Force consider several matters:- Practical "best practice" approaches for determining some minimal level of digital presence that would be treated as a PE. The Task Force should recommend language...