As it was not my place of business
I felt it to be the proper thing to show the money to the proprietor.
The licensee must obtain a permit to practice from the board in the jurisdiction where it has an office that is its principal place of business
In addition, subsection (e) of Article 5(4) provides a general exception excluding the maintenance of a place of business
for activities of a "preparatory or auxiliary" character.
As Wagman notes, if you have a home office that's your principal place of business
, daily transportation expenses incurred in traveling between your residence and other work sites are deductible.
tax only if it is attributable to a fixed place of business
in the U.
Commissioner (101 TC 597, 1993), the Tax Court held a lumberjack could deduct daily transportation expenses even though his only regular place of work was his home and the home did not qualify as his principal place of business
Article 5 of the OECD Model Tax Treaty also distinguishes when, and under what circumstances, the activity within the host country of an agent of the foreign person will establish the requisite nexus to permit direct taxation of the foreign person's business activities by the host country where there is no "fixed place of business
Unless (2) or (3) below applies, however, commuting expenses between the taxpayer's home and a temporary work location within that metropolitan area are nondeductible expenses, because that area is considered his regular place of business
In addition, CPAs will benefit from examples of how the new provisions expand the activities that qualify a home office as a principal place of business
The more important factors to be considered in determining which place of business
is the principal place are the total time that the taxpayer ordinarily spends at each of his business posts, the degree of business activity at each such post and whether the financial return for each post is significant or insignificant; see Rev.
In 1953, the IRS issued revenue ruling 53-190 (1953-2 CB 303), which allowed a deduction for daily transportation expenses between a taxpayer's residence and a temporary work location outside the taxpayer's metropolitan area if the taxpayer has no specific regular place of business
Finally, while stating that, as e-commerce grows, the PE concept may become less appropriate, the paper also notes that it is unclear whether a local and fixed place of business
is the right threshold for taxation in the long term, despite the long history and wide support that the concept enjoys.