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Free cpece webinars
International Tax: United States Permanent Establishments


Cost Free
Presentation Length 1.5 hours

Recorded DateMarch 12, 2020
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Historically, the United States has imposed tax on nonresidents either on income effectively connected to the nonresident’s United States trade or business or (where a tax treaty applies) business profits attributable to a nonresident’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. Evolution of the standard will also be covered, with detail provided on the continuing adaptation of the standard for a digitized economy.

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Patrick is a partner with Culhane Meadows, a national law firm with a prominent practice in the international area.  Patrick practices exclusively in the area of international taxation.  He has extensive experience in 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 international tax issues faced by their clients.

Patrick is a prolific contributor to a multitude of 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 CPA Academy on assorted international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and a 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 both 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.

About Our Presenter

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.