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.

In this episode, David Tuomey and Sean King of Align Global explore the evolving landscape of international tax strategies for US companies, recent disclosures mandated by U.S. regulators, and the myth versus reality of sophisticated tax planning. They discuss how global transparency initiatives are transforming corporate tax practices and what middle-market companies and CPA firms should do today. 

International VAT and GST exposure is one of the most overlooked—and costly—issues facing US companies with international sales. In this episode, we explore why sophisticated buyers flag this issue immediately during M&A due diligence, why tax authorities are now actively pursuing it, and what CPAs need to know to protect their clients.

Featuring industry experts Nick Uren (Senior Manager of International Tax at Aldrich) and Sean King (President of Align Global Consulting, with nearly 30 years of international tax experience), we break down:

✓ The "unintentional expansion" problem: How companies inadvertently create international VAT/GST exposure ✓ The advisory gap: Why traditional corporate tax analysis misses this critical issue ✓ Real-world impact: How unresolved exposure derails M&A transactions and triggers tax authority inquiries ✓ Practical strategies: How to identify, assess, and resolve exposure before it becomes a problem ✓ Your role as an advisor: How to add this to your client advisory checklist and provide genuine value

Whether you're a CPA advising growing companies, a business advisor working with entrepreneurs, or a business owner planning an exit, this conversation will change how you think about international operations.

Key Takeaway: International VAT and GST exposure is real and growing—but it's entirely manageable when addressed proactively.

Guests:

Nick Uren, Senior Manager of International Tax and Transfer Pricing, Aldrich

Sean King, President and Managing Director, Align Global Consulting

Host: David Tuomey - Orsa Saiwai Europe

Join host David Tuomey and specialty tax expert Craig Fouts of Align Tax Consulting for a focused discussion on the top US domestic tax incentives and planning opportunities available to manufacturers entering or expanding in the United States.

The conversation leverages a hypothetical case study—an Italian espresso machine producer establishing a US manufacturing facility—to break down practical, actionable guidance for CPAs and advisors. Topics include:

- Cost segregation studies to maximize accelerated depreciation and 100% bonus depreciation

- The new qualified production property asset class and full expensing of production-dedicated building components

- Updates to R&D tax credits, including restored full expensing of research costs

- Key site selection considerations and state/local incentive opportunities

- Ownership, leasing, recapture pitfalls, and strategies for effective tax planning

Whether your clients are international businesses setting up US operations or domestic manufacturers seeking optimization, this episode provides numbers-driven examples, expert insights, and strategic tips every CPA can use to deliver greater value.

In this essential Orsa Saiwai Podcast episode, host David Tuomey teams up with international tax expert Sean King (Align Global Consulting) to unpack the latest reforms transforming US tax law and cross-border operations for European companies entering the American market.

Get practical, actionable insights on:

• The impact of the “One Big Beautiful Bill Act”: what’s new, what changed, and how it reshapes inbound investment for European businesses.
• The EU–USA tariff agreement: discover how the new 15% ceiling on EU goods affects tax planning, entity choice, and day-to-day operations for manufacturers and distributors.
• Entity structuring tips for CPAs: learn why C Corp is usually the preferred choice, and how to utilize treaty benefits for optimal repatriation and tax efficiency.
• Transfer pricing, IP licensing, and FX risk management: avoid common pitfalls and build structures that protect margins for multinational clients.
• Real-world case study: follow the steps of an Italian manufacturer expanding to the US—understand practical legal and tax solutions from start to finish.

This episode is tailor-made for US-based CPAs advising European clients on cross-border expansion. Whether you need clear answers on recent legislative changes, help assessing optimal business structures, or strategies to limit tax leakage for international operations, this podcast delivers direct advice from experts immersed in the field.

Listen now to sharpen your knowledge, serve your clients better, and stay ahead in the evolving landscape of US–EU tax and trade:

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For questions or to request more detail on topics covered, contact Orsa Saiwai—your trusted partner for hassle-free European expansion and international tax collaboration.

In the podcast David Tuomey from Orsa Saiwai Europe and Sean King from Align Global dive into Section 899 of the proposed "One Big Beautiful Bill Act" (OBBBA), currently under Senate review after passing the U.S. House in May 2025. This episode explores how this pivotal legislation could empower the U.S. Treasury to levy significant new taxes on foreign investors and companies, particularly those from nations perceived as unfairly taxing American businesses. 

We break down the potential impact of measures like Digital Services Taxes (DSTs), the OECD’s Undertaxed Profits Rule (UTPR), and Diverted Profits Taxes (DPT), and discuss how Section 899 could affect a broad spectrum of U.S.-sourced income, including dividends, corporate bond interest, property rent, and profits from U.S. branches of foreign companies. 

Tune in to understand the far-reaching implications for global finance and international tax policy.

In this episode, David Tuomey, Founder and CEO of Orsa Saiwai Europe, joins Sean King, President of Align Global Consulting, to delve into the European Union's Anti-Coercion Instrument (ACI), a pivotal trade defense mechanism designed to counter economic pressure from non-EU countries. Dubbed “Europe’s Strategic Shield Against U.S. Tariffs,” the ACI empowers the EU to respond decisively to economic coercion through measures like tariffs, import restrictions, and market access limitations. David and Sean provide expert insights into how this tool could influence transatlantic trade dynamics and what it means for businesses navigating these evolving policies.

In this episode, David Tuomey, Founder and CEO of Orsa Saiwai Europe, teams up with Sean King, President of Align Global Consulting, to provide a high-level overview of U.S. tax reporting requirements for American companies with foreign entities. With their extensive experience advising North American businesses on international operations, David and Sean break down the complexities of these reporting obligations, shedding light on key compliance challenges and strategies. Whether you're navigating foreign subsidiaries or planning global expansions, this conversation offers essential insights into staying on top of U.S. tax regulations in a globalized business environment.

As the tariffs situation evolves we keep discussing its fluidity 

David Tuomey spoke with Sean King of Align Global on the 4th March, the first day of the implementation of the US Tariffs against Canada, China and Mexico about how businesses can implement potential mitigation strategies around their business operations.