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Old 07-10-2015, 06:57 PM   #11
myway
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Default Re: double taxation online

Thanks FIC, I will do as you advised me. I agree that email would be unreliable in such situations.

Anyway, I'd still like to know whether it is possible for a person who is not a US citizen or resident to make a claim that their business is effectively connected with the conduct of a trade or business in the United States, as it appears the tax rate in that case would be more favorable for them than the dreaded 30% flat rate if the income were deemed FDAP, either by IRS or by the payer.
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Old 07-11-2015, 10:23 AM   #12
Friend In Court
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Default Re: double taxation online

Quote:
Originally Posted by myway View Post
Thanks FIC, I will do as you advised me. I agree that email would be unreliable in such situations.

Anyway, I'd still like to know whether it is possible for a person who is not a US citizen or resident to make a claim that their business is effectively connected with the conduct of a trade or business in the United States, as it appears the tax rate in that case would be more favorable for them than the dreaded 30% flat rate if the income were deemed FDAP, either by IRS or by the payer.
You STILL will need a definitive answer from the IRS for anything anyone else tells you is subject to THEIR interpretation of "doing business" in the U.S. So get your opinion letter directly from the IRS for it will save you a lot of angst and perhaps eventual penalties and fines in addition to delinquent taxes you might have to pay.

I would add that there is a charge for an opinion letter but it should be considerably less than what you would pay a private lawyer for an opinion.
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