Thanks. If there's a subjective test involved, where some things are left to interpretation and circumstantial evidence, my take here is that it would be wises

Thanks. If there's a subjective test involved, where some things are left to interpretation and circumstantial evidence, my take here is that it would be wisest to work with a lawyer/accountant on setting up the correct structure for each engagement. It's also good to remember that this is the IRS, and that other jurisdictions may have entirely different practices here.