International Tax IssuesAnswered

I live in the Philippines and do all the work there. Is that the kind of fact pattern the treaty actually helps with?

AP
ariane_ph_58a7new member
November 13, 2024 2,440 views 1 answer
philippinesremote-servicestax-treatydelaware-llcdesign-servicesno-office

I use a Delaware LLC for design and editing services, but all the work is done from Manila. No U.S. staff, no U.S. office, and no inventory. Most of my clients are in the U.S., which is what creates the anxiety.

I understand no one can give a final treaty opinion from a short message, but I want to know whether this fully remote Philippines-based pattern is the type of setup where the treaty and no-U.S.-office facts are at least directionally helpful.

Related Questions

InternationalAnswered

I live in Indonesia and do everything from Jakarta. Is that the kind of fact pattern the treaty can actually support?

I use a U.S. LLC for a remote design subscription business. All services are delivered from Indonesia, there is no U.S. office, and I have not traveled to the U.S. this year. The clients are mostly Am...

DI
dina_id_7bf7·Nov 19, 2024
2,0801
InternationalAnswered

I live in Australia and run everything from Australia. Is that enough to support a no-U.S.-office treaty view?

I am an Australian resident using a Delaware LLC for a B2B SaaS product. We have U.S. customers, but no U.S. employees, no office, and no U.S. travel this year. All product work and contract approvals...

EA
elliot_au_caf8·Oct 21, 2024
2,5401
InternationalAnswered

I live in Poland and everything is remote. Is it enough to just say that, or do I need a formal facts file?

My U.S. LLC is fully remote from Warsaw and I have no U.S. staff, office, or inventory. Because the facts feel so simple, I was tempted to rely on the story itself instead of building a separate memo ...

OP
ola_pl_4df6·Dec 29, 2024
1,5801
InternationalAnswered

I live in Mexico but spent two weeks closing deals in Texas. Should I expect more Form 8833 discussion now?

I run a U.S. LLC from Mexico City for enterprise software contracts. This year I spent about two weeks in Texas meeting prospects and helping close two accounts. The actual contracts were finalized af...

DM
diego_mx_367a·Nov 25, 2024
2,2101
InternationalAnsweredFeatured

I live in Turkey and do consulting. Should I actually care about U.S. day counts under the treaty tables?

I am a Turkish consultant using a U.S. LLC for software and analytics projects. Most work is done from Istanbul, but I may spend a few weeks in the U.S. this year with one client. I found the IRS trea...

ET
emre_tr_d6fe·Dec 15, 2024
2,1901
InternationalAnsweredFeatured

My clients are abroad but my LLC is in the U.S. Does that automatically make the income foreign-source?

I use a U.S. LLC from Thailand for design retainers and online workshops. Most of my clients are outside the U.S., so I assumed the income must be foreign-source. Then I learned that service income ma...

N8
narin_87a9·Jan 30, 2025
2,7901
InternationalAnsweredFeatured

I am in Brazil and getting 30% U.S. withholding. Is that mainly because there is no treaty?

I use a U.S. LLC for digital licensing and ad revenue. One platform withheld at the full 30% rate and my preparer said Brazil does not have the same treaty path other countries use. I had assumed the ...

RB
renata_br_c557·Oct 19, 2024
3,1701
InternationalAnsweredFeatured

I am in Singapore. Why is everyone telling me there is no treaty path for the LLC?

I run a Delaware LLC from Singapore for software consulting and digital products. Because Singapore is such a major business hub, I honestly assumed there would be some broad treaty path with the U.S....

WS
wei_sg_796e·Nov 7, 2024
3,0101
InternationalAnswered

I live in Spain and made one short U.S. trip. Does that already belong in the treaty file?

I run a U.S. LLC from Madrid for online consulting and had one five-day trip to New York for meetings. No office, no staff, and no contract signing in the U.S. The trip felt too small to matter, so I ...

EE
elena_es_e911·Dec 9, 2024
1,7601
InternationalAnswered

I am in Vietnam and one payer withheld 30%. Is that because I do not have a treaty path?

I run a U.S. LLC for online publishing and some licensing income from Ho Chi Minh City. A U.S. payer withheld at the full 30% rate, and my accountant says the lack of a treaty path is one of the main ...

MV
minh_vn_5cb9·Nov 15, 2024
2,5801

Have a similar question?

ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.

Become a Member — $9.99/mo

Disclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.

Watch the walkthroughs