I (Latin American) opened a US LLC recently, but because of some restrictions related to participating in crypto issuances, I need a company in another jurisdiction. Then it came into my mind of doing a UK LLP of Me + My US LLC.
But one interesting thing that I realized is that because for the UK standpoint the US LLC is considered an opaque entity, if I make the LLC own 99% of the LLP, it means that the tax residency of the LLP will be from US.
This means that I can open a broker in the UK and invest in US stocks, and potentially pay 15% (double-tax agreement between UK-US) or even 0% of witholding tax for dividends, instead of the 30%.
What you guys think about that?
On another topic, what is preferable, having 99% of the ownership of the LLP for the US LLC, or 99% for myself? Would there be difference in trying to get bank accounts / EMI ?
Last edited: Sep 18, 2022
But one interesting thing that I realized is that because for the UK standpoint the US LLC is considered an opaque entity, if I make the LLC own 99% of the LLP, it means that the tax residency of the LLP will be from US.
This means that I can open a broker in the UK and invest in US stocks, and potentially pay 15% (double-tax agreement between UK-US) or even 0% of witholding tax for dividends, instead of the 30%.
What you guys think about that?
On another topic, what is preferable, having 99% of the ownership of the LLP for the US LLC, or 99% for myself? Would there be difference in trying to get bank accounts / EMI ?
Last edited: Sep 18, 2022