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Question

Dear Sir,
I am a non resident alien, a citizen and resident of United Kingdom.
I don’t live in the United States nor do I have a place of business in USA.
However I am selling textbooks online on a US website to customers mainly located in the United States , the sales proceeds of which are credited to my Bank Account in USA as per the requirement of the website.The annual turnover from such sales is about 150,000 $.
I buy my inventory from Asian vendors who ship them out to my handling agent in California who in turn ships out the books against my website sales to the customers address.
I pay him a fixed handling fee per month for his services.
In view of above I need to know if :
A.     This income would be treated as income from a US source .
B.      I am required to file a tax return with the IRS in USA.
I look forward to hearing from you.

Submitted: 59 days and 23 hours ago.
Category: Tax
Value: $30
Status: CLOSED
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Optional Information

Country/State/Province of question: USA/CA

Already Tried:
IRS

Posted by LEV 59 days and 16 hours ago.

Answer

According to the US-UK tax treaty - https://treas.gov/offices/tax-policy/library/uktreaty.pdf

Income that residents of the United Kingdom receive for personal services as independent contractors or self-employed individuals are subject to the provisions of Article 7 (Business Profits) of the treaty. Under that provision, business profits are exempt from U.S. income tax unless they have a permanent establishment in the United States. If they have a permanent establishment available in the United States, they are taxed on the income attributable to the permanent establishment.

 

Having clients in the US does not constitute the nexus unless you actually perform work in the US.

However the fact that you store your inventory in California - means that you have a permanent establishment available in the United States - and all your income should be reported on US tax return. As you are non-resident - you should use the form 1040NR - http://www.irs.gov/pub/irs-pdf/f1040nr.pdf

 

In additional - as you have a nexus (permanent establishment) in California - you are required to register your business in this state, charge and remit sales tax from sates shipped to addresses in California.

You may find more information in this publication - Sales and Use Tax Questions for the Business Person - http://www.boe.ca.gov/pdf/pub53b.pdf

 

Let me know if you need any help.

 

59 days and 13 hours ago.

Reply

I appreciate your reply however I have a couple of more question?I do not have or maintain my own permanent establishment in California,however I have a handling agent handling agent in California who in turn ships out my books against my website sales to the customers address.Does that still construe that I have an establishment/nexus in California?I do not operate as a business but an individual.Do I register with the sales tax authorities as an individual???
Thanks.
Tellena.

Posted by LEV 59 days and 13 hours ago.

Answer

As long as inventory is owned by you - you do maintain a permanent establishment.

The fact that you hire an agent to act on your behalf - doesn't change the situation.

 

The only difference would be - if the inventory is owned by the company or by the agent - in this case that company would have all tax liabilities mentioned above.

 

As you do own an inventory and do have a physical location where this inventory stored - that constitute a nexus in the US and in the state of California.

 

It doesn't matter if you run the business as an individual or have a separate legal entity - rules related to sales tax are same.

 

Let me know if you need any help.

 

58 days and 21 hours ago.

Reply

Thank you just one last question and I will instantly accept the reply. Can you let me know the chapter and page number of the IRS manual which says so and Do I get any foreign earned income exemption under clause 2555.Also would you know a cpa located in Los angeles who can help me with my returns on a retainership basis. Thanks a ton. I anxiously wait to hear from you and release your payment. Tellena

Accepted Answer

Hi Tellena,

Foreign earned income exemption applies to US persons and not to non-residents - so that clause would not apply in your situation. Here are information:

As an US citizen living abroad - you may claim a foreign earned income exclusion.

The person may qualify for the foreign earned income exclusion - he/she should:
-- Work and reside outside the United States for at least 330 days during the year, or
-- Meet either the Bona Fide or Physical Presence tests.
If the person qualifies, he/she may exclude up to $91,400 (2009 in foreign wages -- plus housing allowances (limited to 30% of the earned income exclusion).

To receive that exclusion - the taxpayer should file either form 2555 or 2555EZ.

Here are forms you likely need:

  • 2007 Form 2555
  • 2007 Instruction 2555

Please be aware that - the exclusion above will not affect self-employment taxes - only income taxes. Only earned income is excludable. For instance dividends, investment income, etc - are not excludable.

 

 

Your situation is different - that this would be considered an income from sources in US.

You may want to create a separate legal entity for distribution and have a legal contract with that entity. This way - you will separate US and not US operations.

You may discuss that approach with your accountant.

 

Picture
Expert: LEV
Pos. Feedback: 99.3 %
Accepts: 
Answered: 9/26/2009

Tax Preparer

Taxes, Immigration, Labor Relations

55 days and 23 hours ago.

Reply

Dear Lev, Many thanks for your excellent response.Just one small request.Could you please let me know the para and page number in the manual which supports your above contention.Also would you know of a CPA in Los angeles who could assist me in filing my paperwork. Take care. Tellena

Posted by LEV 55 days and 20 hours ago.

Answer

Hi,

please see IRS publication 519 - http://www.irs.gov/pub/irs-pdf/p519.pdf page 5 for determination of your tax status - resident or nonresident

 

See IRS publication 54 - http://www.irs.gov/pub/irs-pdf/p54.pdf - Tax Guide for U.S. Citizens and Resident Aliens Abroad - page 11 - Who qualify for foreign earned Income exclusion.

See also instruction for form 2555 - http://www.irs.gov/pub/irs-pdf/i2555.pdf on the first page

 

Unfortunately - I may not recommend anyone in LA area.

You may locate a tax office for HRB - use zipcode.

for reference - LA zipcodes you may find here - http://www.mongabay.com/igapo/zip_codes/CA.htm

When you are looking a tax person - mention that you need someone who is familiar with filing for nonresidents.

Ask for option to sign your tax return online without visiting the tax office - if that is more convenient for you.

 

55 days and 20 hours ago.

Reply

Thanks Lev, Actually I meant the chapter where it clarifies that in cases like mine "it is considered that as long as inventory is owned by me - I am considered to maintain a permanent establishment even though it is through an agent." Thanks and take care. Tellena

Posted by LEV 55 days and 19 hours ago.

Answer

Please see for reference - http://www.boe.ca.gov/sutax/outofstate.htm

Persons who are "engaged in business" in California (as defined by Revenue and Taxation Code section 6203) are responsible for collecting and remitting the sales or use taxes on all sales of tangible personal property (unless the transaction is otherwise exempt). Circumstances where a retailer is considered to be engaged in business in California, commonly referred to as "nexus," for sales and use tax purposes include (but are not limited to) the following:

  • Maintaining, occupying or using any type of office, sales room, warehouse or other place of business in California. This includes use that is temporary, indirect or through an agent or other representative.
  • Having any kind of representative operating in the state for the purpose of taking orders, making sales or deliveries, installing, or assembling tangible personal property.
  • Making repairs or providing maintenance or service to property sold, whether by employees, agents or other representatives.
  • Deriving rentals from a lease of tangible personal property located in California.

See IRS publication 519 page 18 - http://www.irs.gov/pub/irs-pdf/p519.pdf

A nonresident alien's income that is subject to U.S. income tax must be divided into two categories:

  1. Income that is effectively connected with a trade or business in the United States, and

  2. Income that is not effectively connected with a trade or business in the United States

The difference between these two categories is that effectively connected income, after allowable deductions, is taxed at graduated rates. These are the same rates that apply to U.S. citizens and residents. Income that is not effectively connected is taxed at a flat 30% (or lower treaty) rate.

Business operations. If you own and operate a business in the United States selling services, products, or merchandise, you are, with certain exceptions, engaged in a trade or business in the United States.

Asset-use test. This test usually applies to income that is not directly produced by trade or business activities. Under this test, if an item of income is from assets (property) used in, or held for use in, the trade or business in the United States, it is considered effectively connected.

Business-activities test. This test usually applies when income, gain, or loss comes directly from the active conduct of the trade or business.

 

 



Edited by LEV on 9/28/2009 at 10:16 PM

55 days and 19 hours ago.

Reply

Thanks Lev, From Sales tax point of view it is very clear .However could you tell me the chapter and page number/link in the IRS manual which explains the nexus situation as in my case for non resident aliens I.e."it is considered that as long as inventory is owned by me - I am considered to maintain a permanent establishment even though it is through an agent." from income tax point of view.Thanks again. Just waiting to accept! Tellena.

Accepted Answer

I do not see the exact reference as you are looking - so we are in the area of interpretation - I suggest to look the publication 519 - see Business operations. (you own merchandise) and Asset-use test. - see the reference above.

 

You also may confirm by calling the IRS directly 1-800-829-1040.

Telephone Assistance for Businesses: 1-800-829-4933

 

Picture
Expert: LEV
Pos. Feedback: 99.3 %
Accepts: 
Answered: 9/28/2009

Tax Preparer

Taxes, Immigration, Labor Relations

55 days and 18 hours ago.

Reply

Ok Thanks. Take care. Tellena.

52 days and 22 hours ago.

Reply

Dear Lev, A question from my handling agent as this is his first such arrangement. As I stated earlier my vendors will be shipping out my books directly to my handling agent in California who will be shown as consignee in the shipping documents.Thus the goods will be cleared form customs in his companys name and the shipping invoice will indicate that I am the buyer and he is the consignee. Would my handling agent be answerable to the Sales Tax authorities in any way.I am given to understand that the Sales Tax authorities write to the importer concerning their Sales tax liability every time a shipment is imported into Los Angeles. Look forward to your usual professional reply. Take care. Tellena.

Posted by LEV 52 days and 15 hours ago.

Answer

Nowadays all states are short on revenue and are very aggressive in collection efforts by all means.

There is an extremely difficult financial situation in California - and while that might depend on the sale volume - we could expect that your handling agent will be contacted by California FTB if there is no registration for sales tax.

 

Here are about responsibility of your agent:

If you make drop shipments or courtesy deliveries to consumers in California on behalf of out-of-state retailers, you are not liable for tax if the out-of-state retailer holds a California seller's permit or a Certificate of Registration - Use Tax. An out-of-state retailer who is required to hold either permit is considered the retailer and is liable for tax.

However, you are considered the retailer and are generally liable for tax if:

-- The out-of-state retailer is not required to hold a California seller's permit or Certificate of Registration-Use Tax, and

-- The retail sale of the property is subject to California sales and use tax

 

You are required to obtain a seller's permit if you are considered engaged in business in California where you sell or lease tangible personal property. If you fail to obtain a permit and file back-due returns, a Compliance Assessment (billing) may be issued based upon the information gathered by the SCOP specialist during and/or after the visit. You will be charged a 10 percent penalty on the taxes due for failing to file a return by its due date. You could also be charged an additional 50 percent penalty if it is determined that you knowingly failed to obtain a permit to evade tax.

You are engaged in business in California if you:
-- Have an office, sales room, warehouse, or other place of business in this state (even if the location is only temporary).
-- Have a sales representative, agent, or canvasser operating in this state.
-- Receive rental payments from the lease of tangible personal property in this state.
There are other activities that may qualify a selling operation as being engaged in business in California. Due to the various rules that apply, you should contact the Board's Information Center XXX-XXX-XXXX or contact your nearest Board office to determine if you must obtain a permit.

 

Let me know if you need any help.

 

48 days and 22 hours ago.

Reply

Thanks lev.I am going ahead and applying for a sales tax permit with California.However should my handling agent in California also apply for one?If questioned by sales tax authorities how does he prove that he is dropshipping fro an out of state seller(me) who would then be holding a sellers permit? Thanks. Tellena.

Posted by LEV 48 days and 22 hours ago.

Answer

Tellena,

If your handling agent will proceed only your transactions - no additional registration required.

But if your handling agent will represent other partners and will do shipping for them - it might be reasonable for your handling agent to apply for a sales tax permit - and do all paperwork.

 

If questioned by sales tax authorities how does he prove that he is drop shipping fro an out of state seller(me) who would then be holding a sellers permit?

He would need to keep a shipping record (with addresses) and receipts from shipping company.

 

Let me know if you need any help.

 

31 days and 7 hours ago.

Reply

Dear lev, Thank you again for your invaluable advise. As suggested by you I have applied for a tax identification number with IRS and shall be applying for registration with the state of California BOE once I have the tax number. I have a quick question.So far I have not collected any sales tax on the Californian Sales as I was not aware of it.Upon registaration with BOE would I be required to deposit Sales Tax with BOE with retrospective effect for Sales which were made to Californian customers.Is there any provision of doing so and would they charge any panalty. As I work on very low margins if I have to deposit this tax from my pocket I will run into losses.Is there any solution to this?. I look forward to your answer. Take care. Tellena.

Posted by LEV 30 days and 19 hours ago.

Answer

As you are selling on a small margin - income tax is not a big issue - but the issue would be a filing requirements on the federal and on the state levels.

The sales tax is imposed on the gross sale.

As you did not charged sales tax from buyers - you may be liable for that amount.

I might suggest to communicate with buyers - assuming you keep track - and ask for California sales tax (with apologies) - I bet some will pay.

 

Also - customers in other states - are responsible to pay use tax on purchases on their own.

Another suggestion - to move your business location to the state which do not have sales tax (if possible) - that will eliminate some overhead - five US states have no sales tax: Alaska, Delaware, Montana, New Hampshire, and Oregon.

 

Sorry for late reply - let me know if you need any help.

 

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