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With reference to Article 7 of the Convention, paragraph 1 of the Protocol refers to the applicability of the Organization for Economic Cooperation and Development (the “OECD”) Transfer Pricing Guidelines, by analogy, for the purposes of determining the business profits attributable to a permanent establishment
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Here's how you know

https://www.irs.gov/node/49746
INCOME TAX Section 6103(l)(21) of the Code was enacted under the Patient Protection and Affordable Care Act, Public Law 111-148 (124 Stat

Here's how you know

https://www.irs.gov/instructions/i1120f
Income Tax Return of a Foreign Corporation Section references are to the Internal Revenue Code unless otherwise noted