USA 100% Foreign partners LLC taxation and related questions

[fcacciola]

Hi,

My partner and I both live in Argentina, and we are merging (the businesses of) our local companies starting an LLC in the state of Florida.

Call our LLC company "A".

Both partners of "A" are non-resident (we live in Argentina).

Though eventually "A" will grow, currently it will have one specific and simple line of bussiness:

"A" LLC will provide computer programming services, billed once a month and by the hour, to US company "B" (with headquarters in Detroit if that matters)

The computer programming service itself will be produced from Argentina as well, by me and two freelance programmers, who also live in Argentina, hired by "A"

The questions I have are:

Considering that the partners of "A" LLC reside in Argentina (and we are all Argentinian citizens with no sort of Visa or such for the US), and the two dependent freelance programmers that will produce the service also reside in Argentina, shall the income of "A" from billing "B" (which is also a US-company) be considered US source, or non-US source? My understanding is that it IS US source (i.e. "A" will have to pay taxes in the US), despite the fact that we are all Argentinian, because the service is provided by US company "A" and not *personally* by the individual programmers involved.

Assuming that the income is US source, is it Effectivly Connected? My understanding is that IT IS, but we are not totally clear about that.

Assuming the income is US-source and ECI, would "A" pay income taxes on any profit based on the bracket table, or do we have to pay a flat tax rate (such as 30%) because all partners are non resident?

For the specific case of the business outlined above, which is just "A" billing once a month to "B" for computer programming services, hourly rated, is there any other tax besides income tax? "A" LLC is registered in the state of Florida.

I have a few more questions but I'll present them as the thread evolves.

TIA

 

[fcacciola]

BTW, I forgot to mention this: we are hiring a CPA, and he will be in charge of the tax returns. We already consulted all this with him but there had been some debate and, I have had mixed experiences with accountants in my years as a businessmen, from which I learn to triple check everything they say and to some extent do. At least until they gain my trust and in this case, we're just getting to know each other.

So, I need the collective help of the forum to make sure all things are correct, hence the questions (with more to follow)

TIA