Bluewings TaxTAX & BUSINESS SUPPORT

PREPARATION GUIDE / UNITED STATES

ECI and FDAP: records for a nonresident income review

Describe the income source and US activities before assigning a tax category. The preparer needs the nature of the payment, business connection and relevant treaty facts to review the treatment.

Preparation resource. Editorial review: November 3, 2026. This guide helps organize records and questions; it does not determine your tax position. Use the agency instructions for the relevant year and obtain advice for your circumstances.

Records to organize

Prepare the records that relate to your situation and keep the original supporting statements. Use the same filing year or clearly labelled periods so the reviewer can follow the history.

  • Contracts and payer statements
  • Description of services, property or business activity
  • US travel, withholding and treaty-support records

How to use these records

Describe the activity and income source before considering effectively connected income or FDAP treatment. Gross withholding and net-basis tax treatment are different concepts. Applicable elections, deductions and treaty positions require a fact-specific review rather than a single rate assumption.

The question to resolve before filing

What income category and filing obligations follow from the actual activity and source?

Start with the facts you can support. Identify missing statements, corrections and earlier filings instead of filling a gap with an estimate that has not been discussed. Tell the team which countries, tax years and agencies are involved so the engagement can cover the right work.

A mistake to avoid

Do not classify every US payment the same way merely because the recipient is a nonresident.

A clear handoff to your preparer

  1. Label the evidence. Keep each record with its relevant year, account or activity.
  2. List open questions. Share missing information and anything that differs from the prior return.
  3. Confirm the scope. Ask which returns, disclosures and follow-up work are included before preparation begins.

Do not enter identity numbers, account numbers, verification codes or tax-document copies in a public enquiry. Use your private client portal for requested records after onboarding.

Official starting points

Use the current agency guidance and the instructions for the applicable filing year. A source link is not confirmation that a particular rule, election or claim applies to your circumstances.

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