Delaware or Wyoming llc vs UK ltd

[parmateruanez]

I need a simple solution that just works.
Since person - me. Russian passport, but not a resident because I left the country several years back.
Consulting. Ecommerce - physical products. Software dev.
Relatively small profits at this stage.

Taxes don't really matter at this point, but as always the less the better.
And privacy - the more the better, but it's not a priority for now.
Paper work and yearly payments - the less, the better.

I've been given advice to open UK ltd. However, I've also seen people talk positevely about Delaware or Wyoming LLC's.
And the US isn't CRS country which is a plus, although there's FATCA, but it's applicable only the US residents, right?

Questions: will Delaware or Wyoming llc work nicely for me? What are their up- and downsides compared to UK ltd?

 

[Willblack]

How do you plan on accepting payments? You will have a much harder time opening a bank/merchant account with a US LLC compared to a UK Ltd.

 

[parmateruanez]

Alex115 said:
How do you plan on accepting payments? You will have a much harder time opening a bank/merchant account with a US LLC compared to a UK Ltd.
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* Transferwise
* Stripe or other payment processors
* directly to a bank

Why "much harder time opening a bank/merchant account with a US LLC"?

 

[user9823671]

parmateruanez said:
Why "much harder time opening a bank/merchant account with a US LLC"?
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Banks don't like foreign owned US LLCs opened in privacy / tax haven US states

 

[fshore]

parmateruanez said:
And the US isn't CRS country which is a plus, although there's FATCA, but it's applicable only the US residents, right?
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Why do you care about this if you are not a resident anywhere?

 

[WoWNull]

parmateruanez said:
* Transferwise
* Stripe or other payment processors
* directly to a bank

Why "much harder time opening a bank/merchant account with a US LLC"?
Click to expand...

i did that and i got a lot of headache, Paypal reject me, and stripe reject me also because i don't have SSN, but last week one of my friend get one LLC and register a Stripe with approval, with her local phone number, and her ID documents ID without any SSN =/ so not sure if Stripe change their things.

 

[JustAnotherNomad]

fshore said:
Why do you care about this if you are not a resident anywhere?
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It's very difficult not to be resident anywhere. It's quite a grey area. Even if you're not resident for tax purposes anywhere, how do you renew your driver's license or passport? What address do you write on immigration forms? Things like health insurance usually require a residency address. It's simply easier to just get residency somewhere, ideally also tax residency. You can still continue to travel, but it's just easier and makes things much simpler.

As for the UK Ltd., there's accounting, right? How much is it? How can you avoid UK corporate income tax? I guess you can pay a high salary, but there will most likely be transfer pricing restrictions.
As far as I know, with foreign-owned US LLC's there are minimal filing requirements if there is no nexus. Might be easier.
Maybe a UK LP could be an option as well? Since they would be taxes like a US single-member LLC/LLP.
Would be interesting to hear some feedback from people who have experience with one of these structures.

 

[MarkRakins]

JustAnotherNomad said:
It's very difficult not to be resident anywhere. It's quite a grey area. Even if you're not resident for tax purposes anywhere, how do you renew your driver's license or passport? What address do you write on immigration forms? Things like health insurance usually require a residency address. It's simply easier to just get residency somewhere, ideally also tax residency. You can still continue to travel, but it's just easier and makes things much simpler.

As for the UK Ltd., there's accounting, right? How much is it? How can you avoid UK corporate income tax? I guess you can pay a high salary, but there will most likely be transfer pricing restrictions.
As far as I know, with foreign-owned US LLC's there are minimal filing requirements if there is no nexus. Might be easier.
Maybe a UK LP could be an option as well? Since they would be taxes like a US single-member LLC/LLP.
Would be interesting to hear some feedback from people who have experience with one of these structures.
Click to expand...

Yeah, not being a resident anywhere is a big headache, we had a client like that, it is not good.

Accounting for a UK Ltd is not that expensive, of course it depends on a bunch of factors, but still.

US companies is something you have to have 100% understanding of what to expect in your particular case. So before pulling a trigger on this one it is always better to seek advice of a CPA.

As regards to the TS questions, we have to know where his current tax residency is, otherwise whatever stuff we suggest does not solve anything for him, unless he plans to report 0 or negative income.

 

[parmateruanez]

MarkRakins said:
where his current tax residency is
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nowhere.

 

[NicolasMaduro]

In my country there is cases like this. A person who travels the world and in theory "isnt tax resident" anywhere. Usually your home country will come and want to collect the taxes that you have paid no where.

Also it doesnt work in practise, since you wont be able to open a bank account or incorporate anywhere ;-)

 

[parmateruanez]

JustAnotherNomad said:
It's very difficult not to be resident anywhere. It's quite a grey area. Even if you're not resident for tax purposes anywhere, how do you renew your driver's license or passport? What address do you write on immigration forms? Things like health insurance usually require a residency address. It's simply easier to just get residency somewhere, ideally also tax residency. You can still continue to travel, but it's just easier and makes things much simpler.
Click to expand...

why are you taling gibberish?

I left my country several years ago.
Am I able to renew my foreign passport? Yes.
What immigration form? When one is arriving to a new country, at a custom? You make me laugh. I can write there whatever I want to, and nobody will care, nor be able to verify. For simplicity I write there my previous address where I lived.

Also, are you talking about residency or tax residency? I think you're confusing the two.
One wouldn't have a residency if he renounced his *citizenship* and thus had no passport at all.

Last edited: May 10, 2020

 

[parmateruanez]

NicolasMaduro said:
Usually your home country will come and want to collect the taxes that you have paid no where.

Also it doesnt work in practise, since you wont be able to open a bank account or incorporate anywhere ;-)
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If that's true, then this forum doesn't exist.

 

[NicolasMaduro]

parmateruanez said:
If that's true, then this forum doesn't exist.
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I think most on this forum don´t want to look over the shoulder the rest of their lives 😀

Also most have come to the conclusion that for example 12,5% tax is better than jail,
or even 0% tax if you go to Dubai

 

[fshore]

parmateruanez said:
why are you taling gibberish?

I left my country several years ago.
Am I able to renew my foreign passport? Yes.
What immigration form? When one is arriving to a new country, at a custom? You make me laugh. I can write there whatever I want to, and nobody will care, nor be able to verify. For simplicity I write there my previous address where I lived.

Also, are you talking about residency or tax residency? I think you're confusing the two.
One wouldn't have a residency if he renounced his *citizenship* and thus had no passport at all.
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So why do you care about crs?

 

[cyprus123]

That somethings works for someone doesn't mean it works for everyone. It makes a big difference in which country you have been tax resident before and if you make just 100.000 EUR/USD/CHF/GBP a year or if serious money is involved.

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[JohnLocke]

NicolasMaduro said:
I think most on this forum don´t want to look over the shoulder the rest of their lives 😀

Also most have come to the conclusion that for example 12,5% tax is better than jail,
or even 0% tax if you go to Dubai
Click to expand...

I totally agree with you, it may be better to look into tax reduction rather then tax avoidance.

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[Spinat]

Does it mean we can avoid to pay corporate tax if we live for instant in France or Germany? I was just wondering, or is it the same regardless where we setup a company we have to pay tax from worldwide income also corporate income?

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[JustAnotherNomad]

blueweb said:
Does it mean we can avoid to pay corporate tax if we live for instant in France or Germany? I was just wondering, or is it the same regardless where we setup a company we have to pay tax from worldwide income also corporate income?
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No, because Germany or France would still demand that you pay local taxes for your permanent establishment (EU branch).

 

[erni]

Do you guys still think the Wyoming company setup is the better choice with Transferwise as banking?

 

[fashionistagirl]

erni said:
Do you guys still think the Wyoming company setup is the better choice with Transferwise as banking?
Click to expand...

I'm set up in Wyoming for the manufacturing division of my company. I really, really don't recommend opening up anything in the US, let alone Wyoming. The reason is because there are HARDLY ANY lawyers in Wyoming who do corporate law, it's IMPOSSIBLE to get ahold of them, and if you ever get sued or deal with a psychotic former employee then you're in murky waters. Wyoming claims to be on track to open a chancery court in 2021 but the reality is that Delaware has a much more established chancery and pro-business mindset. If I were you, then I'd start abroad and open up in Delaware if you 100% NEED to have a division within the USA. I've filed paperwork to move out of Wyoming and into Delaware, but I had to restructure the business and get my butt to the BVI to fix the tax nightmare and legal nightmare. (Word to the wise: do NOT hire random girls off Craigslist who claim to have sewing skills, eye roll.)