NRA Tax Withholding For Foreign Call Centers?

Question

My Call Center is going to start doing bussines with American Companies so I am not sure if I am subject to NRA Withholding. I understand that I am subject to NRA witholding if the property that produces the income is located in the United States or the services for which the income is paid were performed in the United States.

I have the following questions:

1: If a US Telecommunication Company hires me to sell long distance plans for US customers and pays me a commision for each sale, Are those commisions considered as "U.S. Source Income" even though the service was performe in a foreign country?

2: What if a company hires me for handlyng their customer service. Does the IRS Classiflies the Payments I receive as U.S. Source Income or not?

If you can help me I took information from the IRS site
http://www.irs.gov/businesses/small/international/article/0,,id=102317,00.html

Answer 1

I don't know the answer to your question, but I recommend PAYING a professional for an opinion on this issue. You may even request a 'private letter ruling. That basically means you present the facts to the IRS in advance and they issue and official written answer.