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A non-resident alien writes (remotely) a paid-for article for a US based publication. Is that US source income? I think not as per:

https://www.irs.gov/Individuals/International-Taxpayers/Nonresident-Aliens---Source-of-Income

in which it says that for salaries, wages and other compensation, the determining factor is the place where services were performed. So if the article was written outside the US, it is not US source income, correct?

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Income sourced to where the service was performed, so if you didn't write the article in the US - the income is not sourced to the US. The legal definition is in the IRC Sec. 861(a)(3).

  • Ok, so having me officially managed out of an in-country office was about simplifying the company's taxes rather than mine? Good enough. – keshlam Mar 29 '16 at 1:41

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