Re: LLC taxation as a partnership

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Subject Author Date Re: LLC taxation as a partnership Katie 06-12-2007  Re: LLC taxation as a partnership rdrnws 06-18-2007  Re: LLC taxation as a partnership rdrnws 06-19-2007
Posted by Katie on June 12, 2007, 1:07 am Please log in for more thread options > Katie wrote: >>> 2. Do I have to pay federal taxes, state taxes or both >>> (remember I am a non-US citizen residing abroad)? >> Yes, both, and to all states where the LLC provides >> services. You will have income effectively connected with a >> U.S. trade or business, and income with a source in all the >> states where the LLC's activities are taxable. > Would a "foreign earned income" exclusion via form 2555 > apply to me? In a recent thread ("Schedule C Earned Income - > Excluded as Foreign Earned Income"), the general consensus > was that the OP (american citizen living in Japan and > running his Delaware-based LLC from over there) would be > entitled to a federal tax break. > > Would the same apply to a non-US citizen living abroad and > partnering in a US LLC? No, the IRC Sec. 911 exclusion would not apply to you for at least two reasons: (1) it is available only to U.S. citizens or residents; and (2) your income from this activity would not be "foreign earned income" since it would be earned in the U.S. In the previous thread, the OP was working for his LLC in Japan, so his income was earned in a foreign country. Katie in San Diego << ------------------------------------------------------- >> << The foregoing was not intended or written to be used, >> << nor can it used, for the purpose of avoiding penalties >> << that may be imposed upon the taxpayer. >> << >> << The Charter and the Guidelines for submitting posts >> << to this newsgroup as well as our anti-spamming policy >> << are at www.asktax.org. >> << Copyright (2007) - All rights reserved. >> << ------------------------------------------------------- >> Posted by rdrnws on June 18, 2007, 9:28 am Please log in for more thread options Katie wrote: >> Would a "foreign earned income" exclusion via form 2555 >> apply to me? In a recent thread ("Schedule C Earned Income - >> Excluded as Foreign Earned Income"), the general consensus >> was that the OP (american citizen living in Japan and >> running his Delaware-based LLC from over there) would be >> entitled to a federal tax break. >> >> Would the same apply to a non-US citizen living abroad and >> partnering in a US LLC? > No, the IRC Sec. 911 exclusion would not apply to you for at > least two reasons: (1) it is available only to U.S. > citizens or residents; and (2) your income from this > activity would not be "foreign earned income" since it would > be earned in the U.S. > > In the previous thread, the OP was working for his LLC in > Japan, so his income was earned in a foreign country. One small clarification please : I am clear with reason (1) above, but if I am going to be doing work for the LLC from Europe, I do not see why item (2) above would apply. The previous poster was living in Japan but working for a US LLC. I guess I am trying to clarify whether "foreign earned" denotes the geographical location of the earner rather than the geographical source of the income. BTW, what is the title of the IRS publication you are citing above? Thanks again, Nikolas << ------------------------------------------------------- >> << The foregoing was not intended or written to be used, >> << nor can it used, for the purpose of avoiding penalties >> << that may be imposed upon the taxpayer. >> << >> << The Charter and the Guidelines for submitting posts >> << to this newsgroup as well as our anti-spamming policy >> << are at www.asktax.org. >> << Copyright (2006) - All rights reserved. >> << ------------------------------------------------------- >> Posted by rdrnws on June 19, 2007, 9:30 pm Please log in for more thread options Katie wrote: >> Would a "foreign earned income" exclusion via form 2555 >> apply to me? In a recent thread ("Schedule C Earned Income - >> Excluded as Foreign Earned Income"), the general consensus >> was that the OP (american citizen living in Japan and >> running his Delaware-based LLC from over there) would be >> entitled to a federal tax break. >> >> Would the same apply to a non-US citizen living abroad and >> partnering in a US LLC? > No, the IRC Sec. 911 exclusion would not apply to you for at > least two reasons: (1) it is available only to U.S. > citizens or residents; and (2) your income from this > activity would not be "foreign earned income" since it would > be earned in the U.S. > > In the previous thread, the OP was working for his LLC in > Japan, so his income was earned in a foreign country. One small clarification please : I am clear with reason (1) above, but if I am going to be doing work for the LLC from Europe, I do not see why item (2) above would apply. The previous poster was living in Japan but working for a US LLC. I guess I am trying to clarify whether "foreign earned" denotes the geographical location of the earner rather than the geographical source of the income. BTW, what is the title of the IRS publication you are citing above? Thanks again, Nikolas << ------------------------------------------------------- >> << The foregoing was not intended or written to be used, >> << nor can it used, for the purpose of avoiding penalties >> << that may be imposed upon the taxpayer. >> << >> << The Charter and the Guidelines for submitting posts >> << to this newsgroup as well as our anti-spamming policy >> << are at www.asktax.org. >> << Copyright (2006) - All rights reserved. >> << ------------------------------------------------------- >> Similar Threads Posted LLC taxation as a partnership May 29, 2007, 10:45 pm Re: LLC taxation as a partnership June 21, 2007, 5:44 pm Taxation of Non Resident for MA Partnership April 13, 2007, 11:48 pm LLC taxation questions May 25, 2007, 1:41 pm Re: LLC taxation questions May 29, 2007, 10:45 pm Taxation of expatriates June 28, 2008, 5:51 pm LLC Taxation Question April 6, 2009, 7:45 pm Partnership K-1 January 4, 2007, 8:54 pm new partnership April 12, 2007, 12:25 am Taxation Without Representation -- And Worse April 16, 2007, 9:52 pm