Is there any US EMI that is outside the scope of CRS for personal accounts that is reliable?
US LLC + live in Thailand
- Thread starter Roo
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Some countries can deem you as a tax resident (Spain for instance) if you are a national from said country and you have not been tax resident in any other country. They can claim the years where you were not a tax resident anywhere else as a resident in your country of citizenship. That's why it is a good idea to pay some tax in Thailand, have the tax filing and request a tax domicile certificate. Even if you have not been to your country for many years and have no ties. A different matter is if they would notice it and would have interest in going for you.
That's why the UK is great - cuts off after so many months, and then years (5 I think) I had a UK bank doing EDD a couple of years ago after my account being idle and depositing a small amount in to pay for funeral flowers - wanted to know the ins and outs of a donkeys arse hole even when pointing out (they do HMrC business for them now) that I've not been a non resident for well over a decade + they were looking for touch points to bring me onshore or rather to see if there was touch points - apart from a mother about to go 6ft under there wasn't.
I agree, that's why i asked him to verify if EU countries that may consider him tax resident have a DTT with Thailand.
For example Greece, Lithuania, Latvia, Malta and Portugal don't have a DTT with Thailand
https://www.rd.go.th/english/766.html
But a LLC or LLP could either bring you onshore in Thailand or tie you to another nation.
Under Thailand's new rules as both are just an extension of yourself as I understand.
Under Thailand's new rules as both are just an extension of yourself as I understand.
That's true, this risk exists.
The most obvious solution would be to pay somebody in a tax free jurisdiction to manage your US LLC (at least on paper) so it will become tax resident in the tax free jurisdiction.
Yes, I know that in the UK it works like that. But not in every country. Some people think, ok, I am a digital nomad, I spend 2 months in country X, 3 in country Y, 3 in country Z,... and I do not trigger a tax residency anywhere. I can live tax free. Well, that depends on your country of citizenship. For some countries you belong to the state and you are a slave, kind of.
Right. All depends on his passports.
Well, if he worked with the LLC/LLP while in Thailand he would create a PE and the company would be treated as a Thai company. In theory.
Technically - legally speaking British people are not citizens - they are subjects of the crown.
Why not take the income out from the LLC to his own account somewhere around the world?
Because when you transfer money from the LLC to the owner you have to report that amount into form 5472 so IRS knows how much money you have in your name and you don't know how this could be used.
Instead if you don't transfer anything from LLC to yourself you report $0.
Also, you need to open a personal bank account in a non CRS country and this could be not an easy task.
Thank you very much! So it's not for me. I need to transfer all the earnings from the company to myself. If I have a Ltd (outside usa) I can do it easily every time by moving the money out as dividends correct? Thank you
@Marzio that's what I thought in general about 0 tax locations but what about reporting to the IRS? I read that you need to file 5472 and proforma 1120.
I did a bit of reading and found the following so I would still have to report to the IRS any transactions (on onlinetaxman.com - not sure if reliable or not):
Maybe BVI or some similar jurisdiction would be easier in terms of spending directly from the company account or am I wrong here?
I did a bit of reading and found the following so I would still have to report to the IRS any transactions (on onlinetaxman.com - not sure if reliable or not):
Maybe BVI or some similar jurisdiction would be easier in terms of spending directly from the company account or am I wrong here?
Yes that's my question too! I decided to stay far from LLC and USA. But go where? No tax audits/ fillings/ returns per year, no ESR (preferabbly) and no headaches. EU whitelisted or gray listed country that can open a normal company with a director and shareholder. that's it.. where???
Thank you!
@JackieTsan I definitely see the USA/IRS far more serious than places like BVI or SVG that's why I am concerned to incorporate there and then find out I made some mistake and end up paying insane fines.
I was also looking into BVI, harder for banking and it has some very simple filling, the agent didn't seem to know if I need actual accounting like to keep receipts but other than that I think it's less risky and it's not blacklisted by EU, no idea what to pick really.
I was also looking into BVI, harder for banking and it has some very simple filling, the agent didn't seem to know if I need actual accounting like to keep receipts but other than that I think it's less risky and it's not blacklisted by EU, no idea what to pick really.
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