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<h1>Cross-border tax opinion enabling U.S. lab staff in India: Article 5 PE analysis, Article 15 employment withholding guidance</h1> An advisory firm provided cross-border direct tax and compliance guidance to a U.S. government research laboratory's team to facilitate on-site work in India for a bilateral satellite mission. The engagement analyzed the India-U.S. tax treaty to determine tax residency, withholding obligations, permanent establishment exposure, and applicable exemptions, and delivered compliance measures for both the laboratory and its employees to mitigate domestic tax and reporting risks. The opinion and implementation support enabled operational presence in India while addressing treaty benefits and statutory compliance under Indian tax and regulatory regimes.