"MichelleinAtlanta" <me[at]you.com> wrote:

- quote -

There is no foreign earned income exclusion for
corporations; only individuals. So, the corporation must
pay U.S. tax on the Korean income just the same as any U.S.
income. If your client meets the 330-day test, however, he
may be able to exclude a proportionate share of his salary
from his personal income.

Either your client or the company may be able to claim a
foreign tax credit if any Korean taxes were paid.

There are not enough facts here to tell what would have been
best. However, it is an excellent example of a situation
where experience with the foreign exclusion/tax credit rules
could save the taxpayer some money.

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I'm aware of the foreign income exclusion for individuals,
but is there a comparable exclusion for C corps? My client
(a US corp) did consulting work in Korea and billed it
through his corporation.

Does anyone know of any treaty exclusions that might apply
as well?

Michelle E. Botwinick, CPA
Atlanta, GA

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