Does Bitcoin mining through my foreign-owned LLC create a U.S. trade or business?
I'm a foreign national who set up a Wyoming LLC to operate a small Bitcoin mining operation. The mining rigs are physically located in Texas (cheap electricity). I manage everything remotely from abroad.
Does operating mining equipment in the U.S. through my LLC create a U.S. trade or business? If so, all the mining income would be ECI and I'd owe U.S. taxes on it. Is there any way to structure this to avoid ECI, or is mining in the U.S. always going to be treated as a trade or business?
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