My Japanese accountant says my U.S. app income may not all be one category. Why does that matter for treaty withholding?
I am based in Tokyo and have a U.S. LLC that earns app store revenue, ad revenue, and one licensing deal for a software SDK. I had been treating the whole business as 'app income,' but my accountant says the licensing piece could raise a different U.S. withholding question from the app revenue.
I want to know whether that is real or if we are making the structure more complex than it needs to be. Does the treaty analysis actually change when one income stream looks more like a royalty than a service or platform sale?
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