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  1. O

    Offshore Incorporation for Adult Business

    Adult definitely makes things harder. You've got lots of questions to ask first such as: 1. What are your objectives (ie. why go offershore at all? What are you hoping to achieve through this?) 2. How are you accepting payments? 3. What sort of volumes will you be running through the company...
  2. O

    Sticking to Transferwise as EMI, what about the incorporation country?

    Loosely that's correct in practice most income a Singapore company earns will be taxable. Why would you look to Singapore vs some of the alternatives? I love Singapore as a place to visit and live and the banks are fantastic but for forming companies they really aren't a great destination.
  3. O

    Reliable providers for Seychelles/Marshall Islands offshore company

    You'll probably not find someone who will accept Paypal or credit card due to risk of chargebacks. I certainly wouldn't accept that form of payment if I was them as there's no recourse afterwards. You should expect to pay via wire or maybe via crypto.
  4. O

    Is Singapore a good option?

    Super hard to end up with zero tax for a Singapore operating company, essentially not worth it you're far better off going with another option if that's what you're trying to achieve.
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    Cyprus VS Bulgaria VS other - where to incorporate in 2019?

    If they told you that they made a common mistake and that was neglecting a word in the interpretation, which is "in". If you're doing selling IN the US (not to people in the US but rather than sales process is taking place in the US) then yes that would be accurate. You can apply pretty simple...
  6. O

    New incorporation in Singapore

    As a general rule as a foreigner Singapore isn't usually a good place to form a company. I believe someone earlier mentioned HK it's usually a better option for foreigners, there are other options as well but it depends a bit on the nature of your business?
  7. O

    Sticking to Transferwise as EMI, what about the incorporation country?

    France sounds horrible, I'd choose UK 10 times out of 10 over France unless you're actually physically doing business in France. As for the rest, Bulgaria, US, and HK can all have local banking pretty consistently.
  8. O

    Nevis + Bank Account

    Why do you want it to be Nevis? Generally, I'd stay away from jurisdictions like that these days
  9. O

    Cyprus VS Bulgaria VS other - where to incorporate in 2019?

    No, that's inaccurate. Selling to or from US customers does not determine US source income. If that were the case every business around the world selling to the US would be subject to US tax, which is obviously not true. US source income definition varies based on the type of income but loosely...
  10. O

    Cyprus VS Bulgaria VS other - where to incorporate in 2019?

    Look, let this not turn into a dick measuring contest about jurisdictions. As mentioned above there's nothing intrinsically terrible about Cyprus. Probably a lot of people used it in the past because it was easy to get bank accounts. For a long time it was one of the few places you could open...
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    Cyprus VS Bulgaria VS other - where to incorporate in 2019?

    Please see my analysis to Admin listed above. There's nothing intrinsically wrong with Cyprus (except their banks are super shaky so I'd never advise anyone keep more money there than the deposit insurance threshold, which is pretty low, which as mentioned means anyone with a business of...
  12. O

    Cyprus VS Bulgaria VS other - where to incorporate in 2019?

    You should probably be filing 5472 and with it an 1120 (would be rare situations where this wasn't required). Explanation is simple, no trade or business in the and no US source income.
  13. O

    Cyprus VS Bulgaria VS other - where to incorporate in 2019?

    Did you read my description about the reasons I'm not a fan? As mentioned I've rarely found cases where Cyprus is the best option there's almost always been better options. As mentioned the most direct comparison I've typically made when designing structures has been Gibraltar. If I compare the...
  14. O

    Sticking to Transferwise as EMI, what about the incorporation country?

    What exactly do you think governments are going to look at in there?
  15. O

    Sticking to Transferwise as EMI, what about the incorporation country?

    What kind of customers do you have that they care? In my experience it rarely makes a difference unless you're dealing with governments. As an affiliate I've never seen it matter every big affiliate is using one crazy set up or another.
  16. O

    Canadian Tax Planning

    You can't minimize taxes in Canada unless you've got some subtance outside of Canada. You'd need foreign management and control plus the income would need to be foreign sourced (as in the work is taking place outside of Canada).
  17. O

    Where to form an International Trading Company?

    Really critical thing missing from the assessments people are giving you here. You said "licensing those rights to retailers..." This is a huge problem because that's royalties income. Royalties income is usually subject to withholding tax at the source country. So the first thing you'd want...
  18. O

    Subscription Consulting business setup

    The one thing you've got working for you is Mexico sucks at enforcing their rules (unlike countries like Netherlands, Germany, US, Australia, etc.) That being said TIEA really aren't a concern for you. You need to be worried about AEOI/CRS. Mexican CFC rules are fairly easy to avoid, their...
  19. O

    Please tell my why this particular strategy won't work!

    NO, this is not accurate. CFC are a type of laws that many countries around the world have. They are local rules and you need to look at them on a country by country basis. BEPS is a set of recommendations for nations (likewise there's an OECD standard treaty template that is used in most tax...
  20. O

    Please tell my why this particular strategy won't work!

    CFC rules aren't international. In fact aside from exchange of information rules none of the rules we're talking about are international they are domestic. There's something called BEPS the Base Erosion Profit Shifting Action Plan developed by the OCED. BEPS is not law, it is a set of...

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