Disregarded LLC + Portugal NHR/Malta/UK Residency

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hasby2023

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Jul 22, 2023
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Hi all,
I'd like to form a disregarded Delaware LLC as a non US resident to run an Amazon ACX Business and in the future move my residency to a country that doesn't tax foreign income. However, as far as i know, the dividend/distribution from the LLC would be subject to a withholding tax in the US according to the double-taxation treaty between the US and the destination country. I am interested in moving my residency in a non-dom country

Does anyone know if it possible to achieve a similar set-up and live tax-free?

Thanks!
 
Ok such as Portugal NHR. But in this case will the distributions from the LLC be treated as dividends (in this case the WHT will apply, i believe) or like money that i should have already taxed in Portugal (according to the US) and therefore arrive to portugal without any WHT? Thanks!
 
hasby2023 said:
Ok such as Portugal NHR. But in this case will the distributions from the LLC be treated as dividends (in this case the WHT will apply, i believe) or like money that i should have already taxed in Portugal (according to the US) and therefore arrive to portugal without any WHT? Thanks!
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Director's salary in reasonable amount (below 120-150K per year) will do the job.
 
hasby2023 said:
maybe better management fees to avoid hassles with payrolls etc?
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Yes, so, director will be a contractor to the business (you), and you would pay yourself and put it as "Director's Fee" in the statements. There is even an account for this in accounting I think, don't remember. This is what a tax advisor in US told me.
 
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