In April 2011 the 11^th Annual Tax Planning Strategies U.S. and Europe Conference was held at the OECD headquarters in Paris. It was a unique collaboration of the ABA Section of Taxation, the International Fiscal Association, U.S. and Regional European branches, and the IBA Taxes Committee. OECD representatives added an important depth of debate on recent OECD initiatives. One important question actually considered by the OECD Committee on Fiscal Affaires is whether enterprises have passed the threshold for having permanent establishments in host countries. The OECD has a project underway to clarify issues of interpretation of Art. 5 of the OECD Model Tax Convention. One of the panels explored three scenarios that commonly raise PE questions: commissionaire arrangements, subcontracting, and secondment of employees. The panel was chaired by an OECD representative, Stefan Bendlinger was one of the speakers and reports about the outcome of the discussions.