How do I determine if my foreign-owned LLC's e-commerce income is effectively connected income (ECI)?
I've read through all the threads here about ECI and I'm still confused. Everyone says 'it depends on the facts' but no one explains how to actually analyze those facts. I run three different businesses through my foreign-owned LLC:
1. An Amazon FBA store (inventory in U.S. warehouses) 2. A Shopify store selling digital courses (no physical products) 3. Freelance consulting services I deliver remotely from my home in Argentina
Are all three treated the same for ECI purposes? Or could one be ECI while the others are not? I need a framework for thinking about this, not just 'consult a tax professional.'
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