Singapore and Brazil — do these countries have a US income tax treaty for my disregarded LLC?
I'm Singaporean and I'm forming a US LLC. My CPA says Singapore has a wide tax-treaty network so I should be fine. A friend who's Brazilian says he claimed Brazil-US treaty benefits and got reduced withholding. Are these countries actually treaty-eligible?
Related Questions
What is IRC 881 and when does the 30% withholding tax apply to foreign corporations with U.S. income?
My LLC elected to be taxed as a corporation using Form 8832. I'm the sole owner and I live in Singapore. My tax advisor mentioned IRC 881 and said there could be a 30% withholding tax on certain types...
My SaaS revenue from US customers — does Treas. Reg. 1.861-19 classify it as a service or a royalty?
I run a B2B SaaS product from my home country through a US LLC. A withholding agent at a US enterprise customer wants to apply 30% withholding treating my fee as a royalty. I think the current cloud r...
My CPA said IRC 871 governs how I'm taxed as a nonresident alien — what does this section actually cover?
I'm a Japanese citizen running an online marketing agency through a U.S. LLC. I live in Tokyo and have never set foot in the U.S. My CPA said Section 871 of the IRC is the main section that determines...
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 ...
How does the India-U.S. DTAA apply to my disregarded LLC income?
I own a U.S. LLC that earns both consulting fees and some interest income from a U.S. bank account. I understand the India-U.S. DTAA should prevent double taxation, but I'm confused about how it works...
What is the branch profits tax under IRC 884 and how does it apply to foreign corporations?
I'm a foreign corporation doing business in the U.S. through a branch (not a subsidiary). My U.S. tax advisor mentioned something called the 'branch profits tax' in addition to regular corporate incom...
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 ...
I'm from China — how does my U.S. LLC get taxed?
I'm a Chinese citizen living in Shenzhen and I recently formed a single-member LLC in Wyoming for my e-commerce business selling to U.S. customers. I have no physical presence in the U.S. and have nev...
What happens to my 401(k) and deferred compensation when I expatriate?
I have about $800,000 in my 401(k), $200,000 in a traditional IRA, and I'm owed about $300,000 in deferred compensation from my former employer. I'm surrendering my green card next year. My tax attorn...
What is the branch profits tax under IRC 884 and does it apply to my foreign corporation doing business in the U.S.?
I have a Japanese corporation that operates a trading office in Los Angeles. My U.S. tax advisor mentioned a 'branch profits tax' under IRC 884 that would apply on top of the regular corporate income ...
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/moDisclaimer: 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.

