Adsense -> US LLC -> UAE

[FreedomSearcher]

Would this setup be legal?

Google Adsense income -> US LLC (no WTH tax as US LLC is run from outside US) -> UAE Company / Personal bank ACC (no corporate income tax/personal income tax), so effectively 0% total taxation.

I am already a UAE resident and have a freezone company in the IFZA freezone.

The revenue generated exceeds 6 figures a month.

 

[Marzio]

jdcjdc7 said:
Would this setup be legal?
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It is perfectly legal.

jdcjdc7 said:
The revenue generated exceeds 6 figures a month.
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How many sites did you own to generate such a high income with AdSense?

 

[FreedomSearcher]

marzio said:
It is perfectly legal.


How many sites did you own to generate such a high income with AdSense?
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Thanks for answering.

To answer your question, I don't run any Adsense sites. I'm just in the YouTube business.

Where would I set up US bank accounts easily and safely?

 

[Marzio]

jdcjdc7 said:
Where would I set up US bank accounts easily and safely?
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I would try Mercury or Relayfi

 

[FreedomSearcher]

marzio said:
I would try Mercury or Relayfi
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Which state would be best? Heard lots of good stuff about Delaware, New Mexico, Wyoming, etc.

 

[disconnected]

I recently came across this:
https://tax-free.today/us-bank-account/
They are apparently able to open a business bank account with Citibank in Florida remotely. I'm in no way affiliated with them btw. I have no idea about the quality of their service.

 

[Marzio]

jdcjdc7 said:
Which state would be best? Heard lots of good stuff about Delaware, New Mexico, Wyoming, etc.
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I'd go with Wyoming as Delaware is too expensive for what you need and New Mexico could give you problems in opening the bank account.

 

[FreedomSearcher]

marzio said:
I'd go with Wyoming as Delaware is too expensive for what you need and New Mexico could give you problems in opening the bank account.
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Thanks for your useful answers!

One last question I had was which companies do you recommend that assist with filing for the Wyoming LLC?

 

[Marzio]

Those have very good reviews: Wyoming Trust & LLC Attorney - Asset Protection is Our Only Focus

 

[startfleetio]

jdcjdc7 said:
Which state would be best? Heard lots of good stuff about Delaware, New Mexico, Wyoming, etc.
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It's very easy to get everything setup in the US. talk to us on our website. We can help you with the whole process

 

[Mr Gus]

jdcjdc7 said:
Would this setup be legal?

Google Adsense income -> US LLC (no WTH tax as US LLC is run from outside US) -> UAE Company / Personal bank ACC (no corporate income tax/personal income tax), so effectively 0% total taxation.

I am already a UAE resident and have a freezone company in the IFZA freezone.

The revenue generated exceeds 6 figures a month.
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Well there is a very big chance the revenue generated from US ads where normally WTH would have been applicable to could be seen as US source income, so you would still be liable to pay tax on that possibly.

Just get this checked with someone who knows both US and international tax law and don't follow advice from people on this forum.

 

[Marzio]

How in the world clicking on ads could be see as US source income? Source?

 

[Mr Gus]

I am not saying it is, I would just get it double checked.

Pretty sure the US would have put something in place to counter loopholes to avoid paying WTH.

 

[FreedomSearcher]

WIE7 said:
I am not saying it is, I would just get it double checked.

Pretty sure the US would have put something in place to counter loopholes to avoid paying WTH.
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Do you also get Adsense revenue? Which structure have you set up?

 

[Mr Gus]

jdcjdc7 said:
Do you also get Adsense revenue? Which structure have you set up?
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Yes, from YouTube.

I am living on Malta so effective tax of 5% on all income that is not being subject to withholding tax, and 11.6% effective tax on all income that is subject to US withholding tax.

So let's say 50% of your revenue is subject to US WTH and the other 50% is not you will have an effective tax rate of 8,3%.

As far as I know this is the lowest effective tax rate you can achieve without breaking laws and LOB clauses.

 

[FreedomSearcher]

WIE7 said:
Yes, from YouTube.

I am living on Malta so effective tax of 5% on all income that is not being subject to withholding tax, and 11.6% effective tax on all income that is subject to US withholding tax.

So let's say 50% of your revenue is subject to US WTH and the other 50% is not you will have an effective tax rate of 8,3%.

As far as I know this is the lowest effective tax rate you can achieve without breaking laws and LOB clauses.
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Isn't the structure we just discussed the lowest tax? (0%)

Or is there something not very legal going on with this structure?

 

[OffshorePhantom]

I checked and with a UAE company, Adsense applies the 30% WTH since there is no tax treaty between USA and UAE.

Even if you use a US LLC you have to put it as a disregarded entity on AdSense tax-info form and then they ask what is the residential address of the person behind the LLC and if you put UAE then they said there is no tax-treaty and they will apply the 30% tax.

The trick would be to have a company in a jurisdiction with 0 % taxes that has also a tax treaty with the US in order to have a 0 % WTH but I really do not know if this exists since the USA tries to avoid those loopholes.

You could potentially put in the form that the company is a disregarded US LLC (with you as a UAE resident) and then claim a tax-treaty benefit by putting that the beneficial owner is a Portugal based resident for example (Portugal has a tax treaty with the US that avoid the WTH tax), Google allows putting it in the form, the problem is that then it generates a W8BEN-E form which is not true since you are declaring false information (the beneficial owner is from UAE) and if IRS finds out it will be a problem.

Has someone a solution for a 0% tax setup that covers also the WTH tax with the US? Because I do not think it exists currently.

Thank you

 

[Marzio]

hireblade89 said:
Has someone a solution for a 0% tax setup that covers also the WTH tax with the US?
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Goergia seems like a viable option since the US continues to apply the treaty with the former USSR so 0% withholding tax on royalties payments and Georgia is a territorial tax country. If you generate your income while outside Georgia you achieve a 0% setup

 

[FreedomSearcher]

marzio said:
Goergia seems like a viable option since the US continues to apply the treaty with the former USSR so 0% withholding tax on royalties payments and Georgia is a territorial tax country. If you generate your income while outside Georgia you achieve a 0% setup
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I find nowhere online evidence the US has a tax treaty with Georgia, could you please link some sources?

Also, would I have to be a resident of Georgia for that? Or could I put it on someone else's name?
I would like to reside in Dubai if possible. How would I move the profits to UAE?

 

[Marzio]

jdcjdc7 said:
I find nowhere online evidence the US has a tax treaty with Georgia, could you please link some sources?
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jdcjdc7 said:
Also, would I have to be a resident of Georgia for that?
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You could go with the HWNI program but honestly don't know much. if i remember correctly you will not be required to stay 183 days in Goergia to be considered tax resident there.