Week 7 – Eyes on the Prize!
Ruairi Feehan
Aidan and I are working from the client’s offices on a daily basis as the engagement progresses. We are enjoying having direct access to the client. I’m gaining valuable experience in US GAAP and auditing an alternative investments management company is proving to be both challenging and rewarding.
Last Saturday Aidan, Joey, Shaun and I went to Central Park for the afternoon for some relaxation. We threw an American Football around and got some much needed exercise! As you can see in my photo I have my eyes on the prize and needless to say if the Giants need a replacement for OBJ I can step up!
US secondees blog 2019 →EisnerAmper Ireland hosts coffee morning for Daffodil Day 2019
On Friday, 22 March 2019, EisnerAmper Ireland hosted a coffee morning in aid of the Irish Cancer Society for Daffodil Day 2019. We were delighted to support such an excellent cause while enjoying some delicious cakes bought and made by our EisnerAmper Ireland team.
Every year Daffodil Day sees thousands of volunteers selling daffodil pins and flowers on streets, in businesses and homes across Ireland; or hosting a Daffodil Day Coffee Morning to raise funds for the Irish Cancer Society’s nationwide care services for those with, and affected by, cancer in Ireland. For more details or to make a donation, please see the Irish Cancer Society’s website here.
EisnerAmper Ireland, we deliver solutions to support our community.
Corporate Social Responsibility (CSR) is integral to how we do business and manage interactions, not just with our employees and clients but also our wider community and society as a whole. As a professional services firm, demonstrating ethical high performance in all aspects of our work and how we run our firm is fundamental to our success. Learn more about our CSR policy here and our CSR initiatives here.
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Latest News →Week 6 – Broadway!
Aidan Lundy
With the majority of client information received, we began work validating populations to ensure completeness and accuracy on our job. We spent two days at the client’s offices which are located on the west side of the city as well as one day in EisnerAmper’s New Jersey office.
I went to see the Book of Mormon on Broadway last Thursday night which was excellent and enjoyed celebrating St. Patrick’s Day on Saturday but unfortunately there was no Bank Holiday for us here in the USA!
US secondees blog 2019 →Week 6 – St. Patrick’s Day in NYC!
Shaun Boyle
After a short and enjoyable weekend back in NYC for St. Patrick’s Day, Joey Halligan (a fellow Secondee from EisnerAmper Ireland) and I are back at our client’s headquarters in Massachusetts. We’re here with a small team of two to begin revenue and inventory testing.
On Saturday, we got to enjoy St. Patrick’s day in NYC. I had a friend visiting from Ireland so we made the most of the day and went to many different pubs across the city. The next day we took in some of the sites which included a walk through Central Park.
US secondees blog 2019 →What Is Permanent Establishment?
The Irish Revenue* defines permanent establishment as “a fixed place of business through which the business of an enterprise is wholly or partly carried on” and includes it as an article in double taxation treaties which follow the Organisation for Economic Co-operation and Development (OECD) model tax treaty.
As the text of individual double taxation treaties can vary, the relevant article of the appropriate treaty should always be consulted when making a permanent establishment determination.
What Are The Consequences Of Permanent Establishment?
If an enterprise from outside of Ireland is deemed to have permanent establishment in the state, then Irish Revenue has the right to tax the profits of that enterprise.
The taxes which can apply, depending on the circumstances, are:
- Income Tax;
- Corporation Tax; and
- Capital Gains Tax.
Do I Have Permanent Establishment?
Determining permanent establishment is not always straightforward, although article 5 of the OECD model lists the following as indicators of permanent establishment:
- A place of management;
- A branch;
- An office;
- A factory;
- A workshop; and
- A mine, an oil or gas well, a quarry or any other place of extraction of natural resources.
This list is not exhaustive, and even without a physical presence such as those listed above, it is still possible for a business to have permanent establishment, particularly when the business has an agent in Ireland acting on its behalf to conclude contracts.
How EisnerAmper Ireland Can Help
To make a definitive determination we would recommend consulting EAI’s specialist Corporate Tax team for expert advice.
Contact our Tax Team
*Article 5 of Revenue’s Commentary on Irish tax treaties
Latest News →EisnerAmper Ireland staff attend CASSD Gala Ball 2019
The Chartered Accountants Student Society of Dublin (CASSD) hosted their annual Ball on Saturday, 9 March in The Ballsbridge Hotel. Sarah Ryan, a member of EisnerAmper Ireland’s International Business team, is currently Treasurer of CASSD and played a key role in organising the event, which is one of the biggest in the student calendar each year.
CASSD plays a vital role in the student body, providing a link between students and the institute as well as organising numerous events throughout the year.
This year, CASSD chose ‘Empower the Family’ as their sponsored charity. ‘ETF’ supports disadvantaged families in Ireland through education, supporting young disadvantaged single parents in Ireland, with the determination and ability, to successfully complete university. EisnerAmper Ireland was delighted to sponsor staff tickets in addition to donating a spot prize for such a worthy cause.
The evening kicked off with a Prosecco reception, where attendees were greeted by a live saxophone player. The smooth jazz provided a welcoming and relaxed atmospheric back-drop as students took pictures next to a giant, illuminated flower wall.
In the dining hall, students were met by an extravagant ballroom with a goody bag full of treats on each chair. A raffle took place during the dinner with Michéal O’Cualain, a member of EisnerAmper Ireland’s Tax Team winning a Leinster Rugby Jersey, signed by the entire Leinster team. With the band set up, everyone got dancing until late into the night. A great time was had by all.
EisnerAmper Ireland, we deliver solutions to support our community.
Corporate Social Responsibility (CSR) is integral to how we do business and manage interactions, not just with our employees and clients but also our wider community and society as a whole. As a professional services firm, demonstrating ethical high performance in all aspects of our work and how we run our firm is fundamental to our success. Learn more about our CSR policy here and our CSR initiatives here.
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Latest News →EisnerAmper Ireland attends the Chartered Accountants Ireland Annual Rugby Luncheon 2019
On Friday 8 March 2019, EisnerAmper Ireland hosted a table at the Leinster Society of Chartered Accountants Ireland Annual Rugby Lunch in the Aviva Stadium, Lansdowne Rd, Dublin 4. Guests were welcomed with a drinks reception followed by lunch.
The lunch was well attended and the event was a great success. We were delighted to have the opportunity for members of our team to connect with so many clients and friends of our Firm.
At EisnerAmper, we deliver business & compliance solutions to make trade happen.
In this regard, if we can assist you or your business in anyway, please contact a member of our team at +353 1 2933 400.
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Latest News →Week 5 – Irish Visitors!
Joey Halligan
We are now a full month into working on our engagement and the pace is starting to accelerate as we have begun to receive a lot of information from the client. Shaun and I are back at the client’s site in Massachusetts this week and we will be here for another couple of weeks as this is where the majority of the audit field work is being performed.
Last weekend we had our first visitors from Ireland which included our colleagues Kate and Anna. It was a great weekend which included some pizza and wine on Friday night. We are now on the countdown to the real St. Patrick’s Day after having had a taste of what it will be like in Hoboken a few weeks ago.
US secondees blog 2019 →Week 5 – Sightseeing!
Ruairi Feehan
The pace of the job has really picked up over the last couple of weeks and this week I’ve been using EA LLP’s accounting software package to import the various trial balances within the structure I’ve been assigned to. I’m enjoying the opportunity to visit the New Jersey office on a weekly basis and spend time with the Partners and Senior Managers on the engagement.
Last week it was great to see two of our colleagues from Ireland when they came to visit NYC for the weekend. During their visit I managed to sneak in a quick photo of one of the most iconic buildings in New York City, the ‘Flatiron’ Building on 5th Avenue. With St. Patrick’s day this weekend I’m hoping to catch a glimpse of the famous parade!
US secondees blog 2019 →Week 4 – It’s Kicking Off!
Shaun Boyle
Having been in New York and on a client engagement for 2 months now, we’re finally starting to get into substantive testing. As the client structure is very large, we have all been appointed different components. Joseph Halligan, a fellow secondee, and I are specifically working on a component with 35 subsidiaries. We worked from the client’s headquarters in Massachusetts last week and plan to head back again with a team for 2 weeks starting 11 March.
During the weekend we all went to Hoboken, NJ. for what is known as Hoboken Paddy’s Day. As many people commute to New York City for St. Patrick’s day, Hoboken celebrate their St. Patrick’s day on 2 March so as not to lose out on the special occasion! It was a great day out and we’re all looking forward to the real thing next week. Later that day we took a trip to “top of the rock” to enjoy the beautiful view of Manhattan at night.
US secondees blog 2019 →Week 3 – Well and Truly Settled
Aidan Lundy
Coming up on three full weeks here in New York and I am well and truly settled. The engagement is in full swing and we are putting in big hours to ensure we meet our weekly deliverables. We travel out to the New Jersey office at least once a week to meet with the relevant Partners and Directors on the engagement and update them on our progress.
St. Patrick’s Day was celebrated in Hoboken over the weekend. Joseph Halligan, a fellow secondee, and I had a great time at his event two years ago so it was an easy decision to go again. I have visitors from home arriving next week so I’m looking forward to seeing some familiar faces.
US secondees blog 2019 →EisnerAmper Ireland Participate in the Saint John of God’s Community Service Scheme
We are delighted to announce that EisnerAmper Ireland is participating in Saint John of God’s Community Service Scheme. The Scheme was established in Ireland to provide services in the areas of intellectual disability, adult mental health and child and adolescent psychiatry.
Saint John of God is an international organisation providing a range of health and social care services for children and adults. They work in partnership with government departments, health and educational authorities and other statutory and voluntary agencies.
EisnerAmper Ireland, we deliver solutions to support our community.
Corporate Social Responsibility (CSR) is integral to how we do business and manage interactions, not just with our employees and clients but also our wider community and society as a whole. As a professional services firm, demonstrating ethical high performance in all aspects of our work and how we run our firm is fundamental to our success. Learn more about our CSR policy here and our CSR initiatives here.
Contact Us
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