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Recent content by XCD

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    Effectively Connected Income definition for foreign owned LLC?

    There seems to be some disagreement among the several CPAs I asked about this. Suppose I go with one that's more aggressive and says it's not ECI and I dont have to pay US taxes, and a few years later, the IRS audits us & disagrees, what's the worst that can happen? I assume we have to pay back...
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    Effectively Connected Income definition for foreign owned LLC?

    Is there any chance you can recommend a good knowledgeable CPA for this kind of matter? Thanks a lot!
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    Effectively Connected Income definition for foreign owned LLC?

    That was my understanding prior to talking to the CPA. But he claims having a payment gateway (Stripe) and US bank account would render services for US customers to be a US trade and business and therefore subject to US taxes of 21% He says he worked with many foreign owned LLCs in the past...
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    Effectively Connected Income definition for foreign owned LLC?

    We're planning to form a service ecommerce business where people send us their photos, negatives, videotapes, etc for scanning & digitization. My partners and I are all offshore, plan to form a Delaware LLC, and use Stripe & a US bank account to accept payments. Most of our customers will be...
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    Own Delaware LLC vs through offshore corp?

    We’re planning on founding an e-commerce based company, my co-founders and I are all based offshore, and we’re planning on registering a Delaware LLC to enable USD payment, etc. I have come across some articles and YouTube views that suggest the US LLC be owned by another offshore corp, instead...