Permanent Establishment

Andreozzi Bluestein LLP provides representation and guidance to individuals with interests in foreign accounts and businesses.

Permanent Establishment

Andreozzi Bluestein LLP provides representation and guidance to individuals with interests in foreign accounts and businesses.

In today’s global market, businesses are focusing more resources on effectively managing and organizing permanent establishments.  Likewise, taxing authorities, including the IRS, are becoming more aggressive in addressing permanent establishment issues.  As business models evolve, multinational companies face more complex problems in ensuring compliance with tax laws and treaties established under more outdated policy considerations.

Corporations have many options for doing business in a target country without triggering a permanent establishment.  Analysis is highly fact-specific for each case, and the treaty language may vary depending upon the countries that are involved.  When a corporation is expanding its operations into a foreign country, careful consideration of all issues must be taken into account.

The professionals at Andreozzi Bluestein LLP, can address issues and ensure that you are taking the most effective approach toward compliance.  You will meet with our team and director of international compliance to conduct a detailed review of your corporation, with respect to risks relating to maintaining a permanent establishment within the U.S.  These reviews are similar in scope and substance to the IRS permanent establishment examinations.  The review identifies any significant risk factors, advises on corrective action going forward, and assesses the need to file protective or taxable forms 1120F.

Latest News