Welcome Guest. Register Now!  



Reply
 
LinkBack Thread Tools Search this Thread Display Modes
  #1 (permalink)  
Old 08-26-2015, 04:54 PM
Junior Member
 
Join Date: Aug 2015
Posts: 1
Tax liability for WY LLC by Non-US resident

Hi,

What would be Tax liability for WY LLC owned by Non-US resident. Source of Income providing service to US & Canadian clients, although there is tax treaty with our country.

Its 2 member LLC(both aliens).



Digg this Post!Add Post to del.icio.usBookmark Post in TechnoratiFurl this Post!Reddit! stumble!bookmark in google!Share on Facebook!
Reply With Quote
  #2 (permalink)  
Old 08-27-2015, 12:41 PM
Moderator
 
Join Date: Oct 2010
Posts: 5,236
Quote:
Originally Posted by Samy View Post
Hi,

What would be Tax liability for WY LLC owned by Non-US resident. Source of Income providing service to US & Canadian clients, although there is tax treaty with our country.

Its 2 member LLC(both aliens).
As biz entities are always formed under the state law instead of federal law, and each state makes its own laws, the specific rules and requirements are different from state to state. Members of your LLC are taxed on the earnings of the LLC thru SCh k1 of 1065. The treatment of the recipient varies depending on the tax treaty between the US and the country of your domicile. Basically, you must file a return aslongas , you, as a nonresident alien individual, are engaged or considered to be engaged in a trade or business in the US during the year. Generally, when a foreign person engages in a trade or business in the US, all income from sources within the US connected with the conduct of that trade or business is considered to be Effectively Connected Income . This applies whether or not there is any connection between the income, and the trade or business being carried on in the US, during the tax year.Generally, you must be engaged in a trade or business during the tax year to be able to treat income received in that year as ECI. You usually are considered to be engaged in a U.S. trade or business when you perform personal services in the US even though you are NOT physically present inUS. Whether you are engaged in a trade or business in the US depends on the nature of your activities. Deductions are allowed against ECI, and it is taxed at the graduated rates or lesser rate under a tax treaty between US and your country.



Digg this Post!Add Post to del.icio.usBookmark Post in TechnoratiFurl this Post!Reddit! stumble!bookmark in google!Share on Facebook!
Reply With Quote
Ads
Reply


Thread Tools Search this Thread
Search this Thread:

Advanced Search
Display Modes

Posting Rules
You may not post new threads
You may not post replies
You may not post attachments
You may not edit your posts

vB code is On
Smilies are On
[IMG] code is On
HTML code is Off
Trackbacks are Off
Pingbacks are Off
Refbacks are Off


Similar Threads
Thread Thread Starter Forum Replies Last Post
Need help to identify my status - resident or non-resident alien ? shunmuga For 2013 2 03-26-2014 07:23 PM
Tax liability of resident alien nalranj Income 1 08-10-2013 06:10 AM
If a Taxpayer who is a Resident of New Jersey but work's in Pennsylvania, and the employer withheld Pennsylvania income tax from the taxpayers wages, what is impact for the New Jersey Tax Liability? TaxGuru New Jersey 0 01-15-2012 06:00 PM
Oregon 529 tax liability Honeycombkid Education Planning 1 07-01-2011 06:29 PM
C- Corp liability peartree1 C-Corporation 0 02-01-2010 12:21 AM

Follow us on Facebook Follow us on Twitter Google Buzz Rss Feeds

» Categories
 
Individual
 » Income
 » IRA/Sep
 » Medical
 
Corporations
 » Payroll
 
Forum for CPAs
 
Financial Planning
 
 
 

» Recent Tax Q&A
No Threads to Display.