Mike" <moliver[at]unt.edu> wrote:

- quote -

Income for personal services has its source where the
services are performed. If you physically reside in Canada
and wrote the software in Canada, the income is from a
Canadian source, even if paid by a US entity.

If you meet either of the applicable tests, this income may
be excluded under the Foreign Earned Income Exclusion. You
should understand that if you are self-employed, the income
is subject to the social security taxes -- the exclusion is
only applicable to income taxes.

Lanny K. Williams, CPA
Nawarat, Williams & Co., Ltd.
Income Tax Services for Expatriate Americans

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Mike wrote:

- quote -

Found it. See Publication 514, page 12, Table 2. The source
for personal-services business income is based on where the
services are performed. I was programming in Canada, so
it's Canadian-source income.

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

I am a US citizen residing in Canada. I have a modest
amount of business income (freelance software). The
business was conducted in Canada. However, the sole payer
was in the United States. Is this US-source income because
of the location of the payer, or Canadian-source because of
the location of the business?

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >