I'm after a little advice here, which might well be "don't do it you fool".
I'm a UK resident, about to open a new UK LTD, earning about £150k pa from other UK companies. For now, I need to remain resident in the UK, although this may change in a few years, and my clients will not accept invoices from non-UK companies and will only pay into UK bank details (EMI should be OK). My (HMRC declared) pay from the setup should be <= £50k in salary and dividends from UK or foreign sources. Now the tricky part: I want £50k or more to move abroad where it can be invested in shares and crypto with some kept as cash. I also want these assets to be protected from the child maintenance service here in the UK as they will likely decide that it's a diversion of income and include it in their calculations.
My thoughts so far:
A US LLC owns 20% of the UK LTD in class B shares, with me owning the other 80% in class A shares, making me the only PSC. The LLC has one member, being a freezone UAE company with a bit of substance (@Fred's setup perhaps). The UK LTD pays UK corp tax, then dividends based on share class, with £50k of dividends going to the LLC into an EMI account opened with a UAE residence card. The LLC then transfers this from Wise to a local UAE account, which then goes to IBRK, Naga, etc.
I'm hoping this avoids the UK CFC rules as (a) it's only £50k so should be excluded and (b) I'm lucky enough to have a 2nd nationality and TIN, which will be used for the UAE side, with no IRS registration on the US side. I'm more than happy if my old country (Australia) thinks I've moved to Dubai, but a lot less happy if they tell the UK about it as my name and DOB are the same on both passports. I'd rather avoid darks, but happy to use nominees if this would help in any way.
I know I'll need professional advice to progress further, but I'm just wondering if this setup seems doable or if anyone has any other suggestions.
I'm a UK resident, about to open a new UK LTD, earning about £150k pa from other UK companies. For now, I need to remain resident in the UK, although this may change in a few years, and my clients will not accept invoices from non-UK companies and will only pay into UK bank details (EMI should be OK). My (HMRC declared) pay from the setup should be <= £50k in salary and dividends from UK or foreign sources. Now the tricky part: I want £50k or more to move abroad where it can be invested in shares and crypto with some kept as cash. I also want these assets to be protected from the child maintenance service here in the UK as they will likely decide that it's a diversion of income and include it in their calculations.
My thoughts so far:
A US LLC owns 20% of the UK LTD in class B shares, with me owning the other 80% in class A shares, making me the only PSC. The LLC has one member, being a freezone UAE company with a bit of substance (@Fred's setup perhaps). The UK LTD pays UK corp tax, then dividends based on share class, with £50k of dividends going to the LLC into an EMI account opened with a UAE residence card. The LLC then transfers this from Wise to a local UAE account, which then goes to IBRK, Naga, etc.
I'm hoping this avoids the UK CFC rules as (a) it's only £50k so should be excluded and (b) I'm lucky enough to have a 2nd nationality and TIN, which will be used for the UAE side, with no IRS registration on the US side. I'm more than happy if my old country (Australia) thinks I've moved to Dubai, but a lot less happy if they tell the UK about it as my name and DOB are the same on both passports. I'd rather avoid darks, but happy to use nominees if this would help in any way.
I know I'll need professional advice to progress further, but I'm just wondering if this setup seems doable or if anyone has any other suggestions.