Historically, the United States has imposed a tax on non-residents 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.
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 assorted 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.