Case study 1
Late return filed to protect deductions on connected business income
A foreign corporation with a US project had not filed for the periods in which the work was done, and the difference between filing on a net basis and being taxed on gross receipts was the whole question. We assembled the cost side from the company's own project ledgers, established which deductions related to the connected business income, and filed for those periods claiming them, with the reason for the delay set out alongside. The engagement produced the filed returns, a documented cost allocation behind the deductions claimed, and a written position the company can defend if they are challenged.
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Case study 2
Protective returns filed for open periods after a presence question arose
A foreign company reading its own contracts noticed that a US agent had held authority to conclude business for several periods, none of which had been filed. Whether that created a taxable presence was arguable. Rather than resolve the argument internally and file nothing, we prepared returns for the open periods on the footing that preserved the company's deductions and treaty positions, with the agency facts documented. The engagement produced the filings, a memorandum on the agent's authority, and an amended agency agreement, so that the position for later periods is the one the company intends.
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Case study 3
Response to a notice about unfiled foreign corporation returns
A foreign corporation received a notice asking why no US return had been filed for periods in which the authorities could see US-source payments to it. We established what those payments were, whether the activity behind them amounted to a US trade or business, and what had already been withheld. Some periods needed returns and some did not. We filed the ones that did, in date order, and answered the notice with a schedule showing the treatment of each period. The engagement produced the filings and a single written response covering every period in question.
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Case study 4
Unfiled periods found while refinancing a cross-border group
A lender's questionnaire asked a foreign borrower to confirm its US filing history, and the group could not. The timetable was the constraint. We identified which entity had the US activity, built a chronology of when it began, and prepared the returns for the periods carrying exposure first, giving the lender a schedule of what was filed and what was in progress. The engagement produced the priority filings inside the refinancing timetable, a written chronology of the US activity, and a plan for the remaining periods that the lender accepted.
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Case study 5
Overwithheld amounts recovered on returns filed out of time
A foreign corporation had been withheld on at the domestic rate on US-source income across several periods and had never filed, so nothing had been reclaimed. We obtained the payment records from the payers, established which periods remained open, and filed returns claiming the treaty treatment for those, with an explanation of why the filings were late. The engagement produced a recovered withholding for the open periods, a documented treaty position, and corrected documentation lodged with each payer so that the correct treatment applies to payments going forward.
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Case study 6
Historic periods closed after US activity had long ceased
A foreign corporation that had wound down its US operations years earlier had left several periods unfiled, and the point resurfaced when the group was restructured. We established the date the activity ended from payroll records, the last contracts and the closure of the US bank account, and filed the outstanding periods up to cessation, with the wind-down documented. The engagement produced the completed filings, a dated cessation record the group can rely on, and the removal of an open item that had been carried in diligence lists for years.
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Case study 7
Accounts Reported Late When the Income Already Was
Where the income was on the return and only the account report was missed, a narrow route allows late filing with a reason attached. It is open only while no income is unreported and no examination has begun, which is why it is checked first.
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Case study 8
Documentation Requested, and the Deadline Is Not Extendable
Contemporaneous documentation has to exist by the filing deadline, not be assembled when it is asked for, and the penalty protection turns on that timing. The engagement produces the analysis for the year in question and puts a repeatable process behind the next one.
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