As a non-resident alien whos the 100% owner of a Delaware LLC?
First, I assume that you deliver your IT services solely from Jamaica because you state that you provide online IT services . . . to US customers. I assume you dont visit the US to visit with customers or to provide all or a portion of your services. I further assume that you have not made an election to treat your LLC as a corporation for US income tax purposes. Finally, I assume that when you state that you are a non-resident alien you mean from a US perspective. If thats your situation, from a US standpoint your income is taxable solely in Jamaica as things currently stand. The US deems services provided outside the US as being from a foreign source, and as a non-resident alien for US tax purposes you are only taxable on services income with a US source. You, and not the LLC, are deemed the recipient of the income for US income tax purposes because your LLC has only one owner and you havent elected to treat the LLC as a corporation for US income tax purposes. There are no provisions in the tax treaty between the US and Jamaica that affect this result as far as I can tell. I assume that Jamaica then imposes its 25% tax on your when you receive the income from the LLC (or perhaps deems it to flow directly to you as it does for US purposes). If you would like for your income to be taxed in the US you can easily achieve that yourself by making an election for your LLC to be treated as a corporation for US income tax purposes. A US corporation is taxable on its worldwide income regardless of source. Your IT services income would then be taxable in the US. However, this might not be advantageous. While the US federal income tax rate is now 21%, which is lower than the 25% Jamaican tax rate, you could be subject to state taxation. Many states now impose tax on income earned from out-of-state providers if the benefit of the services is received within their jurisdiction. State rates can range from 6% - 10%, and even more. Second, profits distributed from the corporation to you in Jamaica would be subject to dividend withholding tax. Normally the rate is 30%, but under the US-Jamaica tax treaty the rate is only 15% in your situation. Finally, Jamaica presumably would tax you on receipt of the dividends as well at 25%. I dont know if Jamaica provides a foreign tax credit, but if not you are subject to an astronomical tax rate of over 50% when all is said and done. While this answer is not tax advice upon which you can rely for tax planning purposes, it appears to me that you are far better off with your current structure if my assumptions at the start of this answer are all correct.