I've been reading about this stuff for a while. I've just taken myself offshore, and doing a little restructuring. Here's what I've come up with.
U.S. C-corp (Wyoming close corp)
- Billing/marketing face for U.S. clients.
- Wyoming has minimal fees, and close corp keeps paperwork/formalities minimal
- U.S. bank and crypto exchange accounts
- Business activities could be anything, services, media, e-commerce. Can use separate C-corps or LLC subsidiaries.
- No "effectively connected income" concerns regarding U.S. activities. It's definitely taxable in the U.S. Various tax possibilities:
- Take salary directly and applying FEIE = ~15.3% FICA for expat. No additional U.S. taxes for C-corp profits.
- Retain earnings and pay 21% corporate income tax. Seems to have some deferral capabilities up to first $150k-$250k.
- Backdoor IRA and other deductible distributions
- Transfer profits to offshore CFC as management or services fee.
Tax haven IBC, CFC tax treatment (Samoa)
- No ES bulls**t. It matters not at all to me what EU thinks.
- Cheap renewal fees.
- No bank accounts. Could probably get crypto exchange and EMI if needed.
- Crypto and cash only, account for it accordingly
- Owner can pay expenses from personal accounts as contributions, or reimbursements
- Mostly holding company, can contain investments, crypto, forex, whatever.
- Can receive revenue as services fees from separate C-corp, or LLC subsidiary
- Business revenue and investment gains treated as Subpart F (ordinary income rates or 21% flat with election), or paid as salary to owner with FEIE and no FICA, 0% tax rate.
I think this structure would provide a ton of liability protection and tax optimization options. Upkeep costs for this structure are about $100 a month. No subsidiary relationship between the entities keeps it simple.
I did run this by a CPA. They seem to think I'm modeling it right. Would like some ideas from people that have actually done it.
U.S. C-corp (Wyoming close corp)
- Billing/marketing face for U.S. clients.
- Wyoming has minimal fees, and close corp keeps paperwork/formalities minimal
- U.S. bank and crypto exchange accounts
- Business activities could be anything, services, media, e-commerce. Can use separate C-corps or LLC subsidiaries.
- No "effectively connected income" concerns regarding U.S. activities. It's definitely taxable in the U.S. Various tax possibilities:
- Take salary directly and applying FEIE = ~15.3% FICA for expat. No additional U.S. taxes for C-corp profits.
- Retain earnings and pay 21% corporate income tax. Seems to have some deferral capabilities up to first $150k-$250k.
- Backdoor IRA and other deductible distributions
- Transfer profits to offshore CFC as management or services fee.
Tax haven IBC, CFC tax treatment (Samoa)
- No ES bulls**t. It matters not at all to me what EU thinks.
- Cheap renewal fees.
- No bank accounts. Could probably get crypto exchange and EMI if needed.
- Crypto and cash only, account for it accordingly
- Owner can pay expenses from personal accounts as contributions, or reimbursements
- Mostly holding company, can contain investments, crypto, forex, whatever.
- Can receive revenue as services fees from separate C-corp, or LLC subsidiary
- Business revenue and investment gains treated as Subpart F (ordinary income rates or 21% flat with election), or paid as salary to owner with FEIE and no FICA, 0% tax rate.
I think this structure would provide a ton of liability protection and tax optimization options. Upkeep costs for this structure are about $100 a month. No subsidiary relationship between the entities keeps it simple.
I did run this by a CPA. They seem to think I'm modeling it right. Would like some ideas from people that have actually done it.
