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United States · Non-resident A treaty rate applies only once it is claimed

Withheld on the gross, until you say otherwise.

US income paid to a non-resident is withheld at a flat statutory rate on the gross amount, with nothing deducted against it. How that income is classified decides whether that is the end of the story or the start of a very different calculation.

How the income is classified
Passive incomeGross, no deductions
Effectively connectedNet, graduated rates
Which one your income is
US-source income reaching a non-resident
Path A

Fixed and determinable passive income

Dividends, interest, rents and royalties received passively. Tax is taken at source on the gross figure, with no deduction for costs, and withholding is generally the final settlement unless a treaty reduces it.

Withheld at sourceGross basis
Path B

Effectively connected income

Income connected with a US trade or business. Taxed like a resident’s business income — on the net profit after expenses, at graduated rates, and reported on a return you file yourself.

Form 1040-NRNet basis
Why this matters

Gross withholding is the default, not the answer

Four things that decide what you actually keep.

The splitGross versus net changes everythingA business with real costs taxed on gross receipts can owe more than it earned — classification is not a technicality
PaperworkThe W-8 does the workYour payer withholds at the statutory rate unless a valid certificate is on file claiming something better
TreatyReduced rates are never automaticRelief differs by income type rather than applying across the board, and has to be claimed to exist
RecoveryOver-withholding comes back by filingWhere too much was taken at source, a return is the mechanism that recovers it — and it is time-limited
How each path plays out

Three stages, followed down both sides

Almost all of the value sits in the first stage. Once money has been paid at the wrong rate, everything afterwards is recovery rather than planning.

01

Before you are paid

Passive

Give the payer a valid W-8 claiming any treaty rate you are entitled to. Without it they must withhold at the full statutory rate, and correcting that later is slow.

Effectively connected

Establish the position up front so the payer does not withhold as though the income were passive. The certificate you provide is different in this case.

An ITIN, applied for earlyTreaty claims and refunds both depend on having a taxpayer number in place
The treaty article that actually appliesChecked against your country of residence and the specific type of income
02

Through the year

Passive

The payer withholds and remits on your behalf. You should receive a statement showing what was paid and what was taken.

Effectively connected

Nothing may be withheld at all, which means estimated payments through the year rather than a single settlement at the end.

Withholding statements keptThey are the evidence behind any refund claim you make later
State-level exposure checked separatelyStates are not bound by federal treaties and may reach you regardless
03

After year end

Passive

Often no return is required. One is still worth filing where too much was withheld, because that is the only route to getting it back.

Effectively connected

A return is required. Expenses come off, the graduated rates apply, and any tax already withheld is credited against the result.

Form 1040-NR, prepared properlyWith the treaty position disclosed rather than quietly assumed
Refund claims are time-limitedOlder years close off, so a delayed claim can simply expire
The cost of getting it wrong

Most of it is money left behind

No W-8 on file with the payer

Withholding at the full statutory rate on every payment, when a treaty might have reduced it substantially.

Full rate applied
Business income taxed as passive

Gross-basis withholding on receipts, with none of your costs recognised against them.

No deductions
Never filing to reclaim

Over-withheld tax is only recovered by filing, and the window to do it does not stay open indefinitely.

Claim expires
Assuming a treaty covers the states

Federal treaties do not bind individual states, which set their own rules on non-resident income.

No relief
Common questions

What non-residents ask first

Tax was already withheld. Do I need to file at all?

For genuinely passive income, withholding is often the final settlement and no return is required. It is still worth filing where too much was taken, because a return is the only route to recovering the difference. For effectively connected income a return is required regardless of what was withheld.

My country has a treaty with the US. Does the lower rate apply automatically?

No. Your payer withholds at the statutory rate unless a valid certificate is on file claiming the treaty rate, and relief varies by type of income rather than applying uniformly. Getting the paperwork in before payment is far easier than reclaiming afterwards.

How do I know whether my income is effectively connected?

It turns on whether you are carrying on a US trade or business and whether the income is connected to it. Regular commercial activity, people working for you in the US, or a fixed place of business all point one way; a passive holding generally points the other. It is a judgement on the facts rather than a checkbox.

How is this priced?

A fixed fee, scoped from your income types, your country of residence and whether a refund claim is involved. Quoted in writing before any work begins, and never billed by the hour.

Next step

Tell us what you are paid, and by whom.

The type of income and the country you live in decide almost everything here. Send us those two things and we will tell you what should have been withheld, and whether filing recovers anything.

Start scoping