U.S. tax exposure/For established non-US brands

Non-US Brands: Know Your U.S. Tax Exposure Before You Scale.

We map where your U.S. activity actually sits, in the rulebook that applies to you.

Then we align your W-8, W-9, and KYC story across your banks and your marketplaces, so the expensive cleanup never starts.

For brands already selling into the U.S., or about to, on Amazon, TikTok Shop, Walmart, or Shopify.

7,000+ foreign & U.S. founders served since 1997
60+ countries
Amazon SPN & Shopify Partner

The gatekeeper question
You Were Told “No U.S. Office, No U.S. Tax.” That Answer Came Out Of The Wrong Book.

Two rulebooks sit on the table. Most advisors only ever open one of them.







Two rulebooks: U.S. tax law and the treaty, each asking a different question
Book 1: U.S. tax law
Is your U.S. activity considerable, continuous, and regular?

That is the whole question. This book never mentions agents. It applies to every foreign seller, treaty country or not.

Book 2: the treaty
Dependent agent, or independent agent?

This is where “Amazon is an independent agent” lives. It is a real argument. It exists only if your country signed a treaty with the United States.

The mistake

Advisors reach into Book 2 for an agent test, then use it to answer a Book 1 question.

If your company sits in a non-treaty or low-tax jurisdiction, Book 2 was never on your table at all. The answer you were given borrowed authority you do not have.

Courts applying U.S. domestic law have found foreign sellers engaged in a U.S. business without the decision ever resting on the agent test. The agent test was never the domestic test.

Which book produced your answer? Most sellers have never been told there were two.

Where do you stand
Count Your Sticks. Then Notice What They Weigh.

The domestic test is a bundle test. You do not pass or fail on a single fact. Facts accumulate. And they are not equal.

Read down the list. Mark the ones that are true of your business today.







The weight
The stick
Heavy
You own inventory sitting inside the United States.
You sell year-round and restock continuously.
A U.S. person does things for you on your ongoing instructions.
You have a staffed U.S. office or U.S. employees.
Medium
Title to your goods passes to the customer in the United States.
Returns, prep, or repackaging are handled in the United States.
You certified a U.S. operational presence to a marketplace.
Light
A U.S. bank account.
A U.S. business card.
U.S. ad spend.
Zero
An LLC. An EIN. A registered agent address.

These are not sticks. The company by itself created no U.S. tax, and anyone who told you it did was wrong in your favor for once.

The rule
The weights matter more than the count.

Three heavy sticks and two light ones is a different business from six light ones. What your particular bundle adds up to is the question the Blueprint answers, against your facts. We do not guess that from a web page, and neither should you.

Courts have treated this exact pattern, your own goods in U.S. warehouses selling continuously, as a U.S. business for seventy years. No employees and no office required.

Who is actually reviewing you
Five Reviewers. One File. None Of Them Talk.

Five parties look at a foreign-owned U.S. business, independently, on their own schedule, against their own standard.





Five reviewers of a foreign-owned U.S. business, overlapping at one aligned center
Marketplace verification

Get approved.

Ongoing compliance

Stay approved.

U.S. tax

Filed correctly.

Home-country tax

Taxed once.

Banking & payments

Get paid.

Any one of them can impact your profits and stop you. No one will tell you why, or how to fix it.

Trade-offs chosen on purpose. Not discovered later.

Where the failures start
The Questions That Live In The Seams

Nothing breaks in the middle of a system. It breaks where two systems meet and each one assumed the other handled it.

Seam 01
Who signs your W-9, and can a foreign-owned disregarded LLC sign it truthfully?
Seam 02
Where does title to your goods pass, and does that make your income U.S.-source?
Seam 03
Does your home country treat your U.S. LLC as transparent or opaque, and could that tax you twice?
Seam 04
What have you actually filed, and has the clock protecting your old years even started?
Seam 05
If you form a U.S. entity to satisfy one platform, what does that do to the other four reviewers?

These interact. Change one answer and the right structure changes. That is why there is no template, and why this gets mapped rather than guessed.

Your posture, your call
You Choose The Posture. We Map It And Document It.

There is a defensible range, not a single right answer. Where you sit inside that range is a business decision, and it belongs to you.

Conservative

Treaty-friendly positioning. Protective filings. The quietest file, at a cost.

Balanced

Efficiency plus defensible positions, held together by tight documentation.

Aggressive

Higher-yield positions, documented, taken only where the facts support them.

We do not sell positions below reasonable basis.

You decide the band. We map it, document it, and make sure every one of the five reviewers is looking at the same story.

Who builds this
Scott Is The Architect. The Bench Is Licensed.

Scott Letourneau has served 7,000+ foreign and U.S. founders since 1997 and holds the MainStreet Certified Tax Advisor® credential. He is not an attorney and not a CPA. He builds the map, then works alongside licensed international tax attorneys and CPAs who execute inside it.

Scott Letourneau with Marc Schwartz, CPA and JD, international tax

Marc Schwartz, CPA & JD

International tax.

Scott Letourneau with Mark J. Kohler, CPA and Attorney

Mark J. Kohler, CPA & Attorney

Tax and legal.

“I have spoken to several advisors. They are all experienced, but Scott just dives deeper.”

Johnny Lee, U.S. Expat Abroad
Stop guessing which rulebook applies to you.

See how the CEO Blueprint maps this

VERIFIED EXPANSION/by NCP | Since 1997

Educational information only. Not legal, tax, or accounting advice. Positions depend on your specific facts. Scott Letourneau holds the MainStreet Certified Tax Advisor® (MSCTA®) credential and is not an attorney or CPA. Verified Expansion is not a law firm or an accounting firm and does not provide legal or tax advice. We coordinate with independent licensed professionals for legal and tax execution.