Recent content by mmichi

Hi all, I read somewhere that if a tax advisor in EU is asked about "aggressive tax strategies" he would have to report the client to the tax agency. Who decides what is "aggressive" and more importantly how can one consult tax advisors if they are going to report clients? Sounds discomforting...

With regards to the offshore jurisdictions (eg Cayman Islands etc) are there still any decent banks which work with them? I heard that option is pretty much dead. Though I could be wrong. But if I am right, that raises the question: How come 3 out of 4 hedge funds are in Cayman Islands then...

If the LLC is not at all interested in dividends but only capital gains from trading US stocks, what kind of LLC would you suggest? Also, I noticed that you mentioned "I have never got stocks with my LLCs, I prefer to use personal accounts or an offshore business". Can you please elaborate what...

Thanks Sols. Do you happen to know which kind of corporation would definitely not be treated as a "pass-through entity"? Meaning to say which kind of corporation would ensure that the income is not treated as "personal income"? Without going into details: Please kindly read the above question...

Its interesting that you mention "persons, not LLCs". So, do LLCs who trade US stocks pay capital gains taxes in the US?

Thanks, read the thread. The IRS page related to the same seems to be: https://www.irs.gov/individuals/int...gn person,Effectively Connected Income (ECI). Interestingly the page specifically says " NOTE: If your only U.S. business activity is trading in stocks, securities, or commodities...

Thanks. My understanding of "personal income tax" is a tax on "personal income". In the above example, Lenny did not have any personal income. How can he pay "personal income tax"? Yes, there is a case to be made for "Henry LLC" to pay tax in all possible countries, but I do not think that would...

Hi, Based on my research single-member LLCs in Delaware, Wyoming and New Mexico are considered as "Pass-through entities" as far as taxes are concerned. Does this mean that I personally need to pay the tax on the income of the LLC for the year even if I do not pay myself even a single dollar...

Hi all, I was considering a Wyoming offshore LLC. I am a non-US citizen. However, I came across this article where the author claims that one needs to form 2 different LLCs in case one is not really in Wyoming. The example he gave was that of a person named "Steven" who lived in California and...

I think this is a very controversial topic. You can refer the thread below: https://www.offshorecorptalk.com/th...-report-non-us-person-deposits-in-them.22676/If you read the thread it seems that many people believe that its a "one way street", but user "Martin Everson" who does seem to provide...

I am not talking about tax avoidance though. I am referring to someone running a Delaware LLC and paying the proper tax which as per common perception is zero. AND THEN after 10 years USA comes back saying " "look at this tiny footnote here in our tax law". Hence, you owe us a gazillion dollars...

How safe are Serbian banks? I am not referring to the bank failing but rather some employee misusing the bank account of a single person somehow. Basically asking about fraud. Also, another question: Do the Serbian banks allow foreigners to open offshore bank accounts in Serbia remotely? Thanks

Interesting, cause I think I read an article by the Nomad capitalist guy that America did not share data back. But it could be old info. Just as a thought experiment: based on the article you sent, it talks about IRS sharing data. However, what if a non-US citizen has only a bank account in US...

Thanks Martin! so it sounds like it could be retrospective. Effectively, if they agree on 1st June 2021 and publish it in the newspapers for the very first time on 1st June 2021 that they are going to exchange prior data, then it would mean anyone who had an account in March 2021 also gets...

Thanks @bronze. Though I think the "one way street" you are referring to applies to "banks" i.e. CRS. My understanding is that IRS is a completely different entity. Or am I misunderstanding something?