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Culhanemeadows

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UNDERSTANDING PARTNERSHIP TAXATION: TYPES OF BASIS & CONTRIBUTIONS
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Free cpece webinars
International Tax: United States Permanent Establishments

INTERNATIONAL TAX: UNITED STATES PERMANENT ESTABLISHMENTS

Available Date(s)
Friday, July 30, 2021: 9:00AM EDT

Cost Free
CPE Credits 1.5 hours
Subject Area 1.5 - Taxes (Federal Tax)
CE Credits 1.0 hour
Course Id# - HURS9-T-00608-20-O
Course Level Basic
Instructional Method Group Internet Based
Prerequisites None
Advanced Preparation None
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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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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Frequently Asked Questions
  • To receive CPE credit, you must register for the webinar before it starts.
  • CPE is available to all eligible participants within 24 hours of each webinar.
  • To receive CPE for multiple attendees, at least one person must sign up for the webinar. The post-webinar email contains a link to instructions for the proctor letter. Alternatively, you may log in to your account following the webinar and click on the MY ACCOUNT button to find a link to instructions. For paid courses, payment needs to be made for each attendee before credit will be issued.
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Nasba

NASBA Approved

CPAacademy.org (Sponsor Id#: 111889) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222

Irs

EA Approved

CPAacademy.org (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.

CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222

About Our Presenter

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.