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  1. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    The fact that it is extremely rare/unlikely that even a high-tax country like Italy claims you as Italian tax resident (based only on your citizenship if, like you mentioned, you do not have other tax residencies) if you completely cut ties with it and move to Costa Rica and live the whole year...
  2. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    It should be in Costa Rica since he spent the whole year there and has no ties in other countries (I understand that Costa Rica will not see him tax resident there). A country like Italy wouldn't never claim tax residency in Italy (if he is Italian) if he registered to AIRE and have no ties to...
  3. OffshorePhantom

    UAE clarification of Freezone Qualifying Income

    The fact is that the real selling point of UAE was that it is business friendly and law simple and very clear. Now, although 9% CIT is not that high, UAE is transforming and it is no more the same business heaven it was before.
  4. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    And if you are not considered a tax resident because you do not pay taxes in Costa Rica, but you reside the whole year there (and maybe also own a property), where are you consider tax resident? In your home country even if you de-registered from the local population, do not own anything, and...
  5. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    Thailand and some other countries in South East Asia for example. Costa Rica also may be an interesting solution. Panama and Dominican Republic too. You can also consider tax-free countries like Bahamas or Cayman Islands. Before doing any setup also speak with a local tax advisor to check...
  6. OffshorePhantom

    UAE clarification of Freezone Qualifying Income

    What a mess UAE is doing. They made some clarifications but in the end, even with those clarifications, there are still interpretations and speculations on what would be taxed and what not. UAE used to be a straightforward place for business where there were very few laws and they were very...
  7. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    He said he is from a tax-free country so in theory this won't be an issue. Clearly if he enlightens us of what country that is a better advice can be given :)
  8. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    Your freezone company will be subjected to 9% CIT since the company has no substance in UAE if the director/owner of the company (you in this case) is resident in another country. If you live in a tax free company that has territorial taxation it may make sense to adopt other solutions, like a...
  9. OffshorePhantom

    US personal bank account

    They do not open non-resident accounts anymore. You need to have tides to the USA. Hey Johnny, would you mind creating a post on Mentor Gold Group explaining how you where able to get the account? If not possible if you can PM me with some info it would be really helpful, thanks! :)
  10. OffshorePhantom

    personal account Mercury

    Mercury is good for opening an account for your US LLC and it is designed to work with USD only. When you make international transfers you can send money to another currency for a 1% conversion fee though. For personal multicurrency accounts with debit card your best bet would be Wise in my...
  11. OffshorePhantom

    Spain + US based partners running a C-Corp. Looking to optimize income tax.

    Hello, if none of you currently live in Dubai and the Dubai company has no substance this would be seen as a way to avoid paying taxes in your residential country and challenged by the tax authorities. Also if a foreign (in this case Dubai) company is managed by you in Spain or by your partner...
  12. OffshorePhantom

    IT freelance, small incomings in the EU

    I agree, and the billions of dollars that flow to the largest offshore tax even in the world is one thing they want to maintain for sure :) https://www.jrviola.com/tax-news/fa...on-demands-reciprocity-transparency-from-irs/ I guess I know why US still refuses to adhere to CRS (with that...
  13. OffshorePhantom

    IT freelance, small incomings in the EU

    It is unlikely this would happen, especially if you keep the money in US under the LLC name.
  14. OffshorePhantom

    IT freelance, small incomings in the EU

    I do not think they will do it since it is not in their interest (they want to keep money flowing to their offshore system and this would kill it, also the pressure of Europe and other countries does nothing to US since it is not a small Caribbean island). The purpose of form 5472 is for...
  15. OffshorePhantom

    Wyoming LLC holding bonds and stocks - taxable?

    It really depends on the broker and if he presented the LLC as a disregarded entity, some brokers do not deduct at source and so you have to handle the tax payment manually. Also a US LLC is not automatically a disregarded entity, it can be elected as an S CORP, C CORP and also if have multiple...
  16. OffshorePhantom

    Wyoming LLC holding bonds and stocks - taxable?

    Hello, you have to check if the broker already withholds this 30% tax before sending you dividends, if not you have to manually pay taxes on them in the form 1040 that you have to compile and send to IRS if you are the sole member of the US LLC. If the broker already withhold taxes (in the case...
  17. OffshorePhantom

    Malta vs Cyprus vs Estonia vs UAE paired with NHR

    In theory, at least in Italy, if Malta is not in your home country blacklist (or whatever country the tax authority claiming your residency is) it is up to them to find proof that you were not staying in Malta. On the contrary if Malta is on their blacklist it is up to you to prove you stayed there.
  18. OffshorePhantom

    Best offshore jurisdiction for collecting AdSense income?

    Unfortunately, you have to establish your company in a jurisdiction that has a DTT with us in order to avoid the WTH on US purchases or ad views. You can then shift the profits to an offshore entity or UAE company using for example a management contract or something else. This really depends on...
  19. OffshorePhantom

    Malta vs Cyprus vs Estonia vs UAE paired with NHR

    Can you do the same using UK non-dom scheme or it is something peculiar to Malta only?
  20. OffshorePhantom

    Malta vs Cyprus vs Estonia vs UAE paired with NHR

    In those remittance schemes where you are taxed only on the income you remit to the country (also UK non-dom is interesting) is it better to do expenses with a foreign business company card or a personal card of a foreign bank account? Do you have CFC rules? Namely have a company offshore let's...

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