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  1. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    From my personal experience, Mercury and others open accounts for LLCs owned by a UAE resident
  2. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    I am still evaluating the best option to avoid it, probably it will involve a more complex structure with another company in a state that has a tax treaty with USA and then shift the profits. Also my app business income is considered as service income so the WTH in theory, as of my...
  3. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    Usually some services are not available in UAE or have higher fees (like Stripe). In other cases you may want to keep your money in USD instead of AED to avoid later conversion fees to pay things (I know the USD/AED exchange in theory is fixed but in practice there is always a spread so when...
  4. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    Ok so even if you are the manager of the LLC you suggest you can manage it from UAE and probably no one will bother you with the new 9% corporate tax, even if the foreign company is managed from UAE and in theory subject to the new tax. I thought the same, but better be safe than sorry. If they...
  5. OffshorePhantom

    Permanent Establishment rules UAE, with new CT on Companies

    In which countries do you suggest the manager of the LLC be resident to?
  6. OffshorePhantom

    When should I fill out the tax forms in the USA if my LLC is incorporated in January 2023?

    It depends on how the LATAM country sees the company. If the company is managed from a country in LATAM that country can see it as a resident company and thus tax it. It really depends on the country you are in and how things are enforced there.
  7. OffshorePhantom

    Investing in real estate in Dubai, crash course me pls (is it good time, best properties for AirBNB roi etc)

    In my opinion there is still space for growth. The prices have increased a lot so probably do not expect the same growth that the market has experienced in the past 1-2 years but on the long run there is lot of potential. My suggestion is to stick on prime location, namely Dubai Marina, JBR...
  8. OffshorePhantom

    When should I fill out the tax forms in the USA if my LLC is incorporated in January 2023?

    Not necessary, please read my previous posts. It depends if you have a permanent establishment or a fixed place or dependent agent in USA.
  9. OffshorePhantom

    When should I fill out the tax forms in the USA if my LLC is incorporated in January 2023?

    Generally yes, but also take a look that your income is not FDAP (Fixed, Determinable, Annual, Periodical (FDAP) Income | Internal Revenue Service) which may be subject to WTH tax.
  10. OffshorePhantom

    When should I fill out the tax forms in the USA if my LLC is incorporated in January 2023?

    It depends if you have a sales tax nexus or not (What is Sales Tax Nexus - Learn all about Nexus), like I said if you do not have an office, dependant agents or storing facilities in a state it typically doesn't not trigger any sales tax nexus. There was a recent article though that shows that...
  11. OffshorePhantom

    When should I fill out the tax forms in the USA if my LLC is incorporated in January 2023?

    He can even sell products to US residents, this is not a problem. The important thing is that he doesn't not have any US activities, facilities or dependent agent in USA and the services he provides are not connected with a physical business in USA. If he provides personal services or labour...
  12. OffshorePhantom

    When should I fill out the tax forms in the USA if my LLC is incorporated in January 2023?

    My suggestion is to open a Wise or Mercury or Brex account for your US LLC and stick with it, then when you want to distribute profit you can distribute them to your local bank account. You can get payments from wherever you want in the world, even Zimbabwe, the important thing is that your LLC...
  13. OffshorePhantom

    US. LLC, why if I made few sales in within USA?

    No, according to the current laws, at least on the US side. On the other side you have to report that income as personal income in your home country or as company income if the sole member of your LLC is a company instead of an individual.
  14. OffshorePhantom

    US. LLC, why if I made few sales in within USA?

    According to IRS website if there are no reportable transactions there is no need to file the form. Source: Instructions for Form 5472 (12/2021) | Internal Revenue Service
  15. OffshorePhantom

    US. LLC, why if I made few sales in within USA?

    No as for my understanding. The creation and dissolution of the LLC is a reportable transaction though so you have to report it in the form, but that is only a small amount (around $200). You have to report only the money you transfer from the LLC to yourself or a related party. So let's say...
  16. OffshorePhantom

    When should I fill out the tax forms in the USA if my LLC is incorporated in January 2023?

    You need to file FBAR only if your LLC has a foreign bank account, typically you will open a bank account in USA for your LLC so no need to file FBAR. Form 1040-NR is for individual aliens so not for the LLC. If you are, as a person, not resident and do not own any taxes personally to USA...
  17. OffshorePhantom

    US. LLC, why if I made few sales in within USA?

    Having sales in US is not a "reportable transaction", a reportable transaction is by definition a transaction between the members of the LLC (or related parties) and the LLC (or vice-versa). If you make a sale to a client which is not your related party but an independent agent this is not a...
  18. OffshorePhantom

    How will be taxed Pass-through entities in 2023 in the UAE?

    Ok but then what is the purpose of being a UAE resident if you cannot be a tax resident? In that case you will be tax resident in some other places like your home country which will be even worse.
  19. OffshorePhantom

    How will be taxed Pass-through entities in 2023 in the UAE?

    The problem with this solution is that the US LLC is still an independent company managed by UAE and since it is a foreign company in theory it will be subject of the 9% CIT even if the FZ company completely owns it. The issue is on UAE side and not on US side. Hope they found a solution for...
  20. OffshorePhantom

    UAE to introduce 9% corporate tax on business profits from June 1, 2023 (FZCO REMAINS 0%)

    I think that if you are able to registrate the foreign company in a free zone there is no difference between a US LLC and a UK LTD since both will be UAE registered companies for UAE CIT purposes. I read in IFZA website that you can register a branch of a foreign company, but not directly the...

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