Canadian resident's Website Income from US companies

[nelsona]

I would only say that "best" advice and "best sounding" advice are not always the same. A protective return should not worry you however.

And take note of ND's point about state nexus. The states, not handcuffed by treaty, and hungry for revenue because of dwindling sales tax due to interstate on-line selling, are very aggressive on the nexus front.

[JGCA]

I agree with Nelsona that it can be interpreted by IRS staff as either no or yes on the PE question, in my case I have clients in similar situations never entering the US and doing work from Canada online some even have servers in the US. We take the position under the new rules of physical presence in the US over any 365 day perioods that we do NOT have a PE and we file protective 1120F with 8833 statements stating our position . In this case the time clock starts to tick on our assessment timeframe and if need be and we are asked to file then we file and claim all the deductions and tax credits we would be entitked to, had we not files then we would be barred from claiming any deductions and taxed on the gross receipts.
So I would file a protective return it should be done right away to start the clock ticking away.

[xiaoluoj]

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[xiaoluoj]

[quote="xiaoluoj"]It is troublesome that http://www.fut15mall.com/ my quick advice agrees with IRS teleplunkies, making me question myself to my very core.
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