Taxes-by-Rocky
Level 7

Just an observation:

- Has your client established a legal entity doing business in any country other than the US?

- Do the "permanent establishment" or "office or other fixed place of business" rules apply to individual taxpayers?

- Does your client's business have any other income sourced from the US or otherwise?

I"m not suggesting you have some form of "hybrid" structure.....but you might ask if you haven't.