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U.S. Permanent Establishment Analysis

Non-U.S. businesses may find that they can quickly enter the U.S. market to do business. Non-U.S. companies may or may not have U.S. income tax obligations due to their U.S. market activity. Many U.S. income tax treaties contain a Permanent Establishment ("PE") article. The PE article may prevent U.S. federal and certain state income tax liabilities for the U.S. market activity.

Issues to Consider

Will my country's income tax

treaty with the U.S. prevent

U.S. federal and state

income tax liabilities?

Is my company be required to file

U.S. federal and state income

tax returns?

Does my business have a

taxable presence in the U.S.

under U.S. tax law? 

How can we reduce the risk of a

U.S. permanent establishment?

Should my company file a

protective tax return?

Do you need help in understanding if your business has a U.S. permanent establishment?
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