thepensionmaven Posted March 7, 2022 Posted March 7, 2022 Accountant has a client who is not a resident of the US, but has income paid to her LLC. She is in this country more than 90 days each year. Can she set up a qualified plan for the LLC income.
CuseFan Posted March 7, 2022 Posted March 7, 2022 If it is US-source income, then why not? LLC would have an EIN. She should also have a SSN or some other personal tax ID number. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
Jakyasar Posted March 7, 2022 Posted March 7, 2022 Yes as long as US based income. No issues except what happens to the monies once they terminate the plan? All depends on the country they are associated with for taxation. Luke Bailey 1
Peter Gulia Posted March 7, 2022 Posted March 7, 2022 The business owner might want her lawyers’ and accountants’ help to evaluate bilateral and multilateral tax treaties regarding her current domicile, current part-year residences, and current sources of income, and, if different, older-age domicile, residences, and sources of income. While many treaties have provisions meant to limit double taxation, not all do. And timing and accounting differences can result in imperfect application of the treaties’ provisions. Further, the owner/participant might consider current and potential currency restrictions and other difficulties. Jakyasar and Luke Bailey 2 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
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