For a case like Canada and Thailand, since there is a DTT, in theory, can't someone stay in Canada for 5.5 months, and Thailand 6.5 months?
It states that this person will be a tax resident of the country that he has a permanent home.
Thanks for the clarification. What about in the case of a US LLC holding passive investments in Thailand (ie. equities or crypto)? Would that company have any PE risk or tax exposure?
There are other options... how about Panama or Thailand?
UAE doesn't recognize US LLC's as tax transparent. So it sees it as a corporation for tax purposes. Since they're introducing management and control rules, it'll be taxed as if a local UAE company if it's managed here.
For those just holding passive investments - you can just hold the investments personally and be taxed at 0% right?
As long as it's not earned income. Capital gains for individuals are not taxed.