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International Tax: United States Permanent Establishments

INTERNATIONAL TAX: UNITED STATES PERMANENT ESTABLISHMENTS

Cost Free
Presentation Length 1.5 hours

Recorded DateJuly 30, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Historically, the United States has imposed a tax on a non-resident either on income effectively connected to the non-resident’s United States trade or business or (where a tax treaty applies) business profits attributable to a non-resident’s United States permanent establishment. This webinar will provide background on the United States’ historical approach to taxing foreign-based businesses with domestic trade or business activities, looking at the standards for finding a trade or business/permanent establishment. The evolution of the standard will also be covered, emphasizing the continuing adaptation of the norm for a digitized economy.

Learning Objectives: 


  • Identify how the United States imposes taxes on non-residents

  • Recall the United States’ historical approach to taxing foreign-based businesses

  • Determine how to adapt the standard for a digitized economy

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Culhanemeadows

Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick practices exclusively in the area of international taxation. He has extensive experience handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with their clients’ international tax issues.

Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPAacademy.org on various international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law.  His bar admissions include Pennsylvania, Florida, New Jersey, and Georgia.

Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication named Patrick Estate Planning Lawyer of the Year (United States) for 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.

 

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Culhanemeadows
Culhane Meadows is proudly shaking up the legal marketplace by offering exceptional, yet highly-efficient and cost-effective, client services provided exclusively by partner-level attorneys with substantial experience from large law firms or in-house legal departments of respected corporations.