Overview
Uncle Louis generates professional tax memoranda following professional standards. Each memorandum includes mandatory citations, structured analysis, and risk assessment, and is delivered as a Word document saved to your Spaces under My Files.
Memorandum Types
PE Analysis
Permanent establishment risk assessment under treaty and domestic law
Withholding Tax
Cross-border payment classification and treaty relief analysis
Transfer Pricing
Arm's length analysis, DEMPE functions, and TP documentation
Holding Company
Holding structure optimization with substance requirements
Pillar 2 / GloBE
Global minimum tax impact assessment and safe harbour analysis
IP Structuring
Intellectual property migration, licensing, and DEMPE allocation
Memorandum Structure
- 1.Background
Facts, entities, jurisdictions, and transaction description
- 2.Objective
Specific tax questions to be addressed
- 3.Assumptions
Key assumptions underlying the analysis
- 4.Technical Guidance
Applicable provisions in source hierarchy order
- 5.Analysis
Application of law to facts with structured legal reasoning
- 6.Risk Assessment
Conclusion, risk level, and basis per question
- 7.Recommendations
Actionable next steps with deadlines
- 8.Scope Limitations
What the analysis does not cover