Conversations on International Expansion
The Orsa Saiwai Podcast is your ultimate guide for North American businesses and CPAs navigating the complexities of expanding internationally.
Whether you're a business owner looking to explore new opportunities or a CPA supporting clients in their international ventures, this podcast is tailored just for you. essential topics such as tax regulations, HR requirements, and strategic expansion tips are going to be covered
Conversations on International Expansion
Episode 12: A CPA's Guide to Permanent Establishments
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For US-based CPAs advising businesses with any international footprint, Permanent Establishment (PE) is the tax exposure that keeps appearing long after the annual review is done. It shows up in due diligence. It shows up in enforcement letters from tax authorities. And it shows up in deals that fall apart at the final hour because a buyer finds a liability with no statute of limitations and no filed returns.
In this episode, host David Tuomey sits down with Sean King of Align Tax Consulting to give CPAs a straight-talking briefing on what PE is, how to spot it in your clients' operations, and — critically — what to do about it before it becomes your problem to clean up.
Tune in to find out:
• Why your client's PEO or Employer of Record arrangement may create a Permanent Establishment (PE)
• The fact patterns that German, Danish, and French tax authorities are acting on right now
• Why PE exposure with no filed returns means no statute of limitations — and what that does to an exit
• The mitigation conversation you should be having with every client who has international staff
If you have US business clients operating across borders, this episode is essential listening.
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