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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