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If you own a single-member pass-through LLC you're obliged to fill this form too, every year, regardless of it you pay yourself draws or do any payments outside the US. Yes. Even though the US is not part of the CRS, it still exchanges information. If a bank allows you to open a bank account...

Thanks! The IRS will in fact report it to your country of residency as reported on the form 5472 as a foreign-owned LLC. Also for opening a brokerage account in the US a tax id of the authorized person opening the account is required. A foreign tax id, in case of a non-ETBUS LLC. The indication...

Thanks! This forum is gold.

Which countries are the best as a place of residence for a foreign US LLC owner? Sure, many countries have POEM and PE rules, but I'm more interested in how is it reality.

I don't want to sign a new W-8BEN and notify clients each time I decide to move to a new place. Also some clients adjust payouts to the COL in the place of residency.

Given that I can't rely on the rule of law being upheld by these money grabbing leeches, I see the only solution being actually moving to a low tax country, and simply having just the LLC (to access American services) and a holding company (to hide the country of residency on W-8BEN-E from...

Yes, that's why I wrote your sole proprietorship can't be seen as a dependent agent. If no managerial decisions, agreements or contracts are concluded by the sole proprietorship, it's not a dependent agent acting on behalf of the SRL. My country of residency can be notified through the CRS, if...

I think I finally got it. 1) Have an US LLC to sign contracts with US clients and to be able to access US service providers without restrictions. 2) Make it a subsidiary of a Romanian SRL. 3) Manage it all from Romania from the SRL's office, creating a place of effective management of the LLC...

Unfortunately the math does not check out, as they say it's a 300% discount from the tax base, not the tax as given in the example. Therefore you'd end up paying more in fact.

https://helpers.hu/accounting-and-finance/changes-to-taxation-in-hungary-in-2021-and-2022/ https://helpersfinance.hu/how-will-your-taxes-in-hungary-change-from-2022/ New option for reducing the tax base of your company Starting from 2022, you will be able to reduce the tax base of your Hungarian...

Also, how to establish a foreign company in Romania exactly? Only renting an office at a business center and voluntarily registering the company for tax residency seems to be enough, since all work will be outsourced, only management will be performed. No need to setup a representative office...

It looks like POEM rules take precedence over CFC rules in general under BEPS. So POEM rules apply first, company becomes a tax resident, company therefore cannot be a CFC of its local parent anymore since it's not foreign, it will be taxed as a separate entity. So if an LLC subsidiary of a...

Yeah? And what about the LLC's corporate taxation? It can't be taxed nowhere and just pay draws / dividends to the parent and it will be also exempt from taxes. Since it's ran from Romania it's liable for taxation in Romania, now the question is whether as a separate entity or through the...

I'm not sure how this is confirming anything. Once a foreign company has a PE or a place of effective management in Romania it becomes a liable for CIT on profit derived from Romania. This is only about taxation of dividends received, but the profit of the sending company needs to be taxed first.

Well if it's really like this then Romania is a tax haven effectively since the LLC wouldn't be taxed neither in the US nor in Romania.

The last lawyer I asked this: Before proceeding I'd like to clarify how would a US LLC subsidiary of a Romanian micro-entreprise SRL be taxed if it's managed through the SRL parent from Romania? Will it be the 3% / 1% rate as a CFC of the Romanian company or the regular rate as a separate...

So I'd ignore these "advices" to be on the safe side. Now the question is if the LLC will be taxed with the standard CIT or the 3% / 1% revenue tax if it's a subsidiary and a CFC of a Romanian SRL micro-enterprise with a POEM there.

Yes hard to believe. No one gave me any reasoning, all the lawyers and accountants who replied only told me it won't be liable for any taxation, only if draws are paid, which will be considered dividends. The treaty clearly says: (1) Industrial or commercial profits of a resident of one of...

I just got confirmed by a yet another Romanian lawyer that an US LLC operated from Romania would not be liable for any tax in Romania. Weird considering what's written in the tax treaty. Th ANAF never replied with their clarification.

Why didn't he deliver? What's so hard about forming a company? Or is this just a standard low level of quality of services? The services I found online look often carelessly put together with spelling mistakes etc