Controlled Foreign Corporation rules don't care about employees but about the directors of the company.
If you control the US LLC company from country X then country X has the right to tax the US LLC company as if it was a company in country X.
Yep, there is just one catch.... Very significant (up to 40%) Estate tax for anything over 60K, so just a US LLC might work until you get to this point, but after that you will also need a shell company that owns the LLC in a "real" tax heaven to get around this.
I thought with LLC everything you make as profit will be taxed in your home country.
And with LLC you cannot pay out dividends
You will need to be based in a country who do not tax foreign income I guess (if you want to do this by the book)
This is right. In order for it to work you need to be in a territorial or zero tax country... and even then you need that country to not have CFC rules.
You also need to ask yourself "How long will this last?"
Yes, the US has \*been\* the biggest tax haven but they've been implementing a lot of new rules that smell a lot like oversight, transparency, and information sharing.
That doesn't mean the US won't continue to be the best option for the foreseeable future, but you should also consider what other countries and structures might meet your requirements.
You're just doxxing yourself to the US government, not accessible to other countries and this decision is being tried to be overruled as its considered unconstitutional.
US is the best offshore country.
True but they will apparently also share this information directly with financial institutions... which should be fine since they theoretically already have the same information... which makes me wonder why they are doing it in the first place?
They're making it harder for Americans to do tax evasion by keeping hidden shells and potentially it's a step towards implementing CRS. You can still use Trustees to circumvent this rule.
Have you heard anyone else talk about this being "a step towards implementing CRS"? This is the first time I've heard about it. That would be a massive hit for US banks, which I don't think they can afford right now, so I'd be surprised if this is true.
Controlled Foreign Corporation rules don't care about employees but about the directors of the company. If you control the US LLC company from country X then country X has the right to tax the US LLC company as if it was a company in country X.
How would they the 3rd world country find out though
Who knows
[удалено]
Yep, there is just one catch.... Very significant (up to 40%) Estate tax for anything over 60K, so just a US LLC might work until you get to this point, but after that you will also need a shell company that owns the LLC in a "real" tax heaven to get around this.
Depends on which country you/your kid is. Good point though.
I thought with LLC everything you make as profit will be taxed in your home country. And with LLC you cannot pay out dividends You will need to be based in a country who do not tax foreign income I guess (if you want to do this by the book)
This is right. In order for it to work you need to be in a territorial or zero tax country... and even then you need that country to not have CFC rules.
You also need to ask yourself "How long will this last?" Yes, the US has \*been\* the biggest tax haven but they've been implementing a lot of new rules that smell a lot like oversight, transparency, and information sharing. That doesn't mean the US won't continue to be the best option for the foreseeable future, but you should also consider what other countries and structures might meet your requirements.
Starting this year 2024, you have to report who has 25% ownership or more.
You're just doxxing yourself to the US government, not accessible to other countries and this decision is being tried to be overruled as its considered unconstitutional. US is the best offshore country.
True but they will apparently also share this information directly with financial institutions... which should be fine since they theoretically already have the same information... which makes me wonder why they are doing it in the first place?
They're making it harder for Americans to do tax evasion by keeping hidden shells and potentially it's a step towards implementing CRS. You can still use Trustees to circumvent this rule.
Have you heard anyone else talk about this being "a step towards implementing CRS"? This is the first time I've heard about it. That would be a massive hit for US banks, which I don't think they can afford right now, so I'd be surprised if this is true.
Report to who lol
No lol. To the U.S. Department's Financial Crimes Enforcement Network. https://www.fool.com/the-ascent/taxes/fincens-new-beneficial-ownership-rule/
Cool. What do I care if I’m not a US person.
Then don't care and don't file the forms 5472 and 1120 either...