DOCUMENTATION
Memoranda
Overview
Uncle Louis generates professional tax memoranda following professional standards. Each memorandum includes mandatory citations, structured analysis, and risk assessment.
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
Facts, entities, jurisdictions, and transaction description
Specific tax questions to be addressed
Key assumptions underlying the analysis
Applicable provisions in source hierarchy order
Application of law to facts with structured legal reasoning
Conclusion, risk level, and basis per question
Actionable next steps with deadlines
What the analysis does not cover