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#Form 1120-F

Plain-language notes on U.S. tax deadlines, IRS letters, cross-border reporting and running a small business, written by the CPAs who handle these questions every day.

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Going global: US companies · Nov 9, 2026

AliExpress Overseas Managed: With Inventory in a U.S. Warehouse, Does the Chinese Company Owe U.S. Tax? Form 1120-F, the Treaty and a U.S. Subsidiary

Under AliExpress's overseas managed model, the platform prices and runs the listing, but goods sit in a U.S. warehouse and the seller ships them, so the inventory is generally the seller's until sale. A Chinese company that imports and sells from U.S. stock likely has effectively connected income, looks to the U.S.–China treaty and files Form 1120-F with Form 8833; state taxes don't follow the treaty. Many sellers use a U.S. subsidiary instead.

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Going global: US companies · Nov 9, 2026

Inventory in CastleGate: State Nexus and U.S. Income Tax Risk for Foreign Wayfair Suppliers

When a Chinese factory places goods in Wayfair's CastleGate warehouses, it has physical presence in each inventory state, which can bring sales tax registration and franchise tax, and states generally ignore the U.S.-China treaty. Federal tax turns on ECI: produced inventory is generally sourced where it's made, but a U.S. office, staff or agents can change that.

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Going global: US companies · Nov 9, 2026

Making Kirkland Signature Products in China: When Does the Factory Owe U.S. Tax? FOB, DDP, §863(b) and Permanent Establishment

A factory producing in China and selling FOB China to Costco generally has foreign-source income under §863(b) and usually no U.S. income tax. DDP, U.S. inventory, U.S. staff or a U.S. office can create effectively connected income and a Form 1120-F filing, which is why many factories supply through a U.S. subsidiary.

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Going global: US companies · Nov 9, 2026

Chinese Sellers Using Shipped by Newegg: No Newegg Importer of Record, and Is There U.S. Income Tax?

Newegg won't act as importer of record for SBN inventory, and inbound shipments must be DDP. A Chinese company selling continuously from SBN warehouses in California and Indiana is generally in a U.S. business; the U.S.–China treaty can protect storage-only activity, but usually requires Form 1120-F with Form 8833, and state taxes aren't covered.

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Going global: US companies · Nov 9, 2026

Supplying Perigold From an Overseas Furniture Factory: Contract Directly or Set Up a U.S. Company?

Perigold uses Wayfair's supplier agreement, which overseas companies can sign, but it requires a North American warehouse and is not the importer of record. Supplying directly puts importing, storage and collections on the foreign company and may mean Form 1120-F; a U.S. C corporation is smoother but files Form 1120 + 5472 every year.

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Going global: US companies · Nov 9, 2026

From SHEIN Supplier to Your Own Brand: Keep Supplying, Form a U.S. Subsidiary, or Go Semi-Managed? Who Pays the Tariffs and U.S. Tax

As a SHEIN supplier, SHEIN prices, sells and imports, and the factory generally files nothing in the U.S. Selling your own brand changes that: a U.S. subsidiary imports and sells, files Form 1120 and 5472 and needs arm's-length purchase prices; a Chinese company selling semi-managed from a U.S. warehouse faces trade-or-business questions and often a 1120-F with Form 8833.

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