Thank you for your response. I new I could count on you more than support.

"because your client had US-ECI, most likely by virtue of having been present in the US conducting business (albeit without a PE)" No presence in the U.S. He sells retail products through a fulfillment partner.

Business was conducted as foreign-owned U.S. LLC. Therefore no W8-BEN-E or W8-ECI is issued because business is conducted with a U.S. LLC with an EIN. A 1099-K was issued to the EIN that the LLC uses.

Help me Obi-Wan Kenobi, you are my only hope.