Thailand 0% tax

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I would switch my account to︁ IBKR US. Maybe I’m paranoid but I don’t want one of the most corrupt countries︂ in the world having access to how much money I have plus my address when︃ they report it through CRS.
 
well said. But to have ibkr us you need a residency which is there,⁤ like Dubai for example, but afaik Georgia has Ibkr usa too. All asian ones ought⁣ to be ibkr hk, so will do crs unless one is resident in hong kong⁢ itself.

They have your address by other means already and theres widespread face rec but︀ yeah, i would not wanna have crs reports sent to these asian countries where im︁ physically present. Maybe only some uncomplicated low-ish balance is ok.
 
To avoid the CRS the best thing to do is to open an account with IBKR⁢ U.S. or Charles Schwab U.S. under an LLC.

By having the account under an LLC,︀ you also get rid of the U.S. Estate tax.
 
Here’s a summary of the⁠ tax treatment of UCITS with respect to U.S. withholding:

Ireland-domiciled UCITS ETFs: These UCITS ETFs,⁤ listed in the EU, benefit from a tax treaty between Ireland and the United States.⁣ As a result, the withholding tax on dividends from U.S. securities is reduced to 15%⁢

Accumulating UCITS ETFs: Some UCITS ETFs are structured as accumulating funds, which means dividends are︀ reinvested within the fund rather than being distributed to investors. This can help minimize tax︁ liabilities, as investors do not receive dividend payments and are not subject to withholding taxes.︂
 
Maybe my explanations wasn't clear.⁤ Current situations :

1) with my actual portuguese address (on IB), i don't have any⁣ WHT (0%) on dividends received from Ireland/UK ETFs domicilied (included all basics MSCI world vanguard,⁢ ishares etc...).

2) I have 15% WHT tax on dividend stocks directly linked to US︀ (as for mostly everyone I think)

3) For cash interest (USD) it's still linked with︁ Ireland, BUT there is still a 15% WHT on the interest (as i understood/know it's︂ not linked with US).

My question was if by putting Thailand address the WHT tax︃ of Ireland-UK ETFs still stay at 0%. And If also you can do it at︄ 0% WHT for the cash interest.
For the 2) I think anyway it's stay at︅ 15% for anyone (except US citizen-resident / LLC)
 
Are there any negative repercussions to holding my IBKR assets under a US LLC? Currently,⁤ all my assets are in my name. I'm contemplating establishing a US LLC to transfer⁣ my assets, providing an additional layer of protection since the assets would not be directly⁢ under my name. I was under the impression that US Estate tax would still apply,︀ but you have just confirmed that this is not the case, which is positive. I︁ do not care much about the CRS in this case, so it is not really︂ relevant, but it does not harm.

However, regarding capital gains taxes, dividends, etc., I'm uncertain︃ if this would trigger taxable events in the US, as the asset owner would be︄ the LLC, potentially qualifying as ETBUS despite being a disregarded entity.

In a nutshell: what︅ are the advantages and disadvantages of forming a New Mexico LLC solely for holding investments︆ in IBKR, compared to owning the investments personally? My investments are exclusively in Ireland-domiciled ETFs.︇

TIA!
 
You need to find the DTA between Thailand and Ireland/UK.

Good questions.....

Correction, under a Single Member LLC (SMLLC) you are️ still subject to the Estate Tax.
Under a Multi Member LLC (MM LLC) you are‌ not subject to the Estate tax as the MMLLC has two or more members.
Some people are going the extra mile by having a MMLLC owned by a foreign Corporation,‍ such as a Panamanian company, a foreign company cannot die.
I only have a MMLLC,⁠ and my CPA tells me that's enough to get rid of the Estate Tax.

By having the account under an LLC or a MMLLC you are NOT subject to Capital⁤ gains Tax, or any type of Tax in the U.S. as the LLC is a⁣ passthrough entity. So you would have to pay taxes in your country of residency (if⁢ your country of residency has those taxes, if not, everything you make is tax-free.)

You are still subject to the withholding tax on dividends received, and that is based on︀ the DTA between the U.S. and your country of residency.

Hope that helps.
 
Thanks! That's what I thought. I︄ did some research some time ago and I read that a SMLLC is still subject︅ to the Estate Tax. Although I assume that transferring the company to a relative while︆ still alive would not be subject to the Estate Tax. Not sure though. I will︇ have to look into that.
 
This is not correct, unless you treat the LLC as a corporation and has more⁤ than one shareholder.

If it’s a pass through entity it will have estate taxes.
 
Yes, that's the whole point why those funds are domiciled in⁠ Ireland/Luxembourg: There is no WHT.
The funds gets access to the US treaty, so the⁤ US WHT is reduced to 15%, but then that's it, as Ireland/Luxembourg don't impose additional⁣ WHT.
That's what attracts those funds there. It's not a coincidence they're all domiciled there.⁢

Yes, that's per the tax treaty︁ between the US and Ireland/Luxembourg.

If you own the US LLC︇ directly, everything owned by the US LLC will fall under US estate tax.
If you︈ own the US LLC through a foreign corporation, the estate tax risk goes away because︉ the foreign corporation cannot die. But there's a risk of branch profit tax in the︊ US if you do any kind of operations in the US.

No. The DTA can︌ only reduce taxes, not add new taxes. But the WHT is already 0% for Ireland/Luxembourg.︍
 
All those ETFs based in Ireland suffer from tracking error, it's way︃ better to own U.S. ETFs.
 
US ETFs have estate tax (unless you hold them through a foreign entity) and also‌ potentially 30% WHT (unless they are swap-based, I think).
 
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