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§00Classification · Glossary

Effectively Connected Income

Also called ECI

Income from a U.S. trade or business taxed at graduated rates after deductions, rather than the flat 30% FDAP withholding.

In full

Effectively Connected Income (ECI) is income earned by a foreign person that is attributable to the conduct of a U.S. trade or business. Unlike FDAP income — which is taxed at a flat 30% (or treaty-reduced) rate on the gross amount — ECI is taxed at graduated corporate or individual rates on net income after deductions. Classification turns on the facts of the business itself: whether there is a dependent agent, a fixed place of business, and how the underlying assets and activities are actually used.

Governed by: U.S. trade or business rules.

This definition is general information about how the term is used in U.S. cross-border tax. It is not advice, and how it applies depends on your own facts and on the treaty, if any, in force with your country.