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No, this option mentions running a company tax resident in Malta tax free. You can then decide to become a Maltese non dom and pay 5K max on all the income you keep outside Malta.

I'd say this is the solution you are looking for: https://corriericilia.com/publications/resident-non-domiciled-companies

AFAIK those taxes impact natural persons and companies to the extent that their income is taxable in Estonia so Estonia can still be used as holding location (if you don't plan to sell your company)

It means that foreign sourced income shouldn't be deposited in Ireland. And BTW if your plan is to manage an offshore company from Ireland thinking that "income from outside Ireland it's foreign sourced income" you'll find yourself in deep trouble. Foreign sourced income is generally passive...

Well don't know all the names but i heard at least 100 in 24 hours. Last edited: Dec 23, 2024

Every foreign owned US LLC has to file form 5472 and nobody knows how IRS will use that data. It could be that they will never share anything or it could be that they will share only with some countries or it could be that at some point they will start sharing with all their partners.

C'mon even boys in mom's basement have to eat! :p

The point is that in the article the author explicitly states that you can overcome the problem of having invoices accepted since those are coming from the Canada EPC. Branches are taxed on local income because we all suppose that are used to serve the local market and if you invoice an...

I still think there's more to the extra provincial corporation thing. Ok the article i linked contained some errors mentioning one time that EPC is a branch and a second time that's a subsidiary but it clearly said that EPC was tax free. OP lawyer confirmed that the setup is tax free but not...

That's why i involved Canada in the equation from the beginning. I'll take that as a compliment :cool: He said he doesn't want to.

He said BVI will hold IP/hardware/assets so i assume BVI will license those to US LLC that will pay royalties. If that's the case it's 100% passive income. Agreed. It will cost him around 20K/30K yearly to put in place a structure like that and he will still find himself in a grey area by...

The US LLC and BVI companies will be tax resident in Canada if you manage them from Canada. To avoid that you will need to create substance in a friendly jurisdiction so that the companies will not be considered tax resident in Canada. Depending on what you do US LLC income could be consider...

Probably but it was a fun experiment :p

Nothing will flow back to you as i said, profits will stay indefinitely at the EPC level. Barbadian company will have it's own local director for the company and you'll be the one working the day to day operations in Canada as the EPC manager. Well knowing that's possibile to reside in Canda...

The Barbadian company requires a local director so i guess this part is already solved. Honestly Canadian CFC rules are some of the strangest s**t i've ever encountered BUT even in case CFC rules will be a problem theres's a loophole for that too! Simply the EPC will never send back money to...

Why not? It's not like he is managing the offshore company from Canada pretending to not be tax resident in Canada. His offshore company will form an EPC to do business where he lives. He will do business throught the EPC. The day to day activities will be performed by him in Canada. The...

Better ask a really good one and even seek a second advice. Please report to us your findings.

Yes, read the article. it says that the EPC will have its own tax identification number, Canadian business address and it will be able to open bank accounts. So it's a PE without tax any implications if it doesn't do business in Canada. As i said this has to be verified but i thought it...

Yes, he is managing the company from Canada through the EPC registered in Canada. Not sure what Monaco has to do with it.

If that's the case this is a prime opportunity to test out one of the Canada greatest loopholes i ever read. This is what i would do: I would form a company in Barbados and then an EPC in Canada where I will be managing the daily operations. Your EPC will deal with Canada banks so you can...