C-Corp as partner of MMLLC with non-resident
I have single member LLC that I plan to convert to multi-member by adding C-Corp that I've created so I could shift some income to it that I could then cancel with deductions allowed by US rules which are not allowed in my country.
Would having US C-Corp as a partner cause any real risk of MMLLC being considered engaged in US trade or business? I'm doing consulting from abroad for US client, C-Corp has no assets/people in US and I would still be manager of the LLC. C-Corp's role would be to basically act as EoR and give me deductible fringe benefits.
My understanding is that as long C-Corp has no people working on behalf of MMLLC on US soil partnership won't become ETBUS
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Michal Opoka
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C-Corp as partner of MMLLC with non-resident
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