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- QBI brain teaser US source income S/E US citizen living overseas
QBI brain teaser US source income S/E US citizen living overseas
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Drphibes
Level 7
07-02-2020
09:30 PM
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Hold on to your bottoms for this one.
US citizen, U.S. SMLLC (disregarded) consulting company, he is living overseas (all year) and taxed on his income by host country. He is in the taxable income phase out range for QBI as a SSTB. From what I see in the rules for QBI, it has to be U.S. connected business (all income is from the U.S. and from US companies and he pays guys for doing a chunk of the consulting work in the U.S.). Since he lives overseas for 12 mo, he gets Foreign Income Exclusion since it where he is living/working which is taking place as far as what is considered "foreign income" definition for the exclusion and Foreign Tax Credit. In addition, any income over the Foreign Exclusion and Housing Deduction can be used for foreign tax credit. Anyone find a hole in this logic. I have not been able to.
Thanks in advance!
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