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@Nickster I'd be interested in discussing this

Hi all, Imagine you currently live in UAE, a tax resident there and have a company in a Free zone. Let's say to start that you are the sole shareholder. You move to the US in September or October 2023 with the intention to work and live there for a couple of years. 1) Would you be liable for...

Have you considered 1. Applying for the "lavoratori impatriati" regime in Italy? If you move to the south, 90% of your taxable income from freelancing will be exempt (70% in the north). I believe it is not compatible with the "regime forfettario" so at your level of income I am not sure what...

Can you tell us more about that case? Was that resident the sole owner in the UAE company or a minority shareholder? Was there a director and substance in UAE?

Hmmm, I'm not that sure. I agree that approach would be less risky, of course, but that paragraph of the law doesn't state you have to have strong economic ties to the country. The problem I see is that the wording is quite ambiguous, since it talks about maintaining a residence in such...

So how many days would you have to stay to qualify? You talk about "some time". How long is that? is it open to interpretation by the tax office? Is one day enough? Is one month? This is what the law says exactly: b) Tendo permanecido por menos tempo, aí disponham, num qualquer dia do período...

Why would you be abusing the NHR? If the law explicitly states that a person is a tax resident in PT if: "Regardless of spending less than 183 days in Portugal, maintains a residence (i.e. a habitual residence) in Portugal during any day of the period referred above" you'd be abusing the law...

Good and important question

Oh, I had the same question but I was told by several people that in many cases the tax authority will place the burden of proof on you. Apparently, they will say we assume you are an active shareholder, prove us wrong. To me it does not make a lot of sense as they should be the ones to provide...

What do you mean?

Yes, I was talking about the EU partner only taking money out as dividends. If that's the case, the tax authority might still want to check that they are truly a passive shareholder, not doing any active work for the company. Taking money out as salary shouldn't be a problem; you pay income...

I'd be potentially interested too. Are you talking about having for instance two (or more) partners with a company in a FZ in UAE with office space and perhaps employees? Imagine, as an example, one of the partners owns 60% of the company and is a resident in Dubai. The other partner owns 40%...

Only if the tax burden can be lowered by deducting costs necessary for running the drug business, such as invoices from hitmen, for instance ?

I do not think that's accurate. If you read any FATCA agreement between the US and a EU country you will see the US reports several types of accounts, including personal accounts.

So for a tax resident of the UAE, what is the big advantage of this structure vs having a FZC? The reputation of a UK company?

It looks like the "regime forfettario" (what gives you that flat 15%) is not compatible with the lavoratori impatriati regime, as confimed by the tax office: Fisco agevolato per gli impatriati e regime forfetario sono In any case, I have spoken to a couple of Italian tax advisors and they all...

But the premise is that the US LLC will make no profit, so even if it were considered a tax resident in Romania, 16% of $0

Were they raiding company offices only or residential property as well?

What country was doing the audit? And what kind of money were they looking to tax? I'm guessing a large multiple of that $100K in legal fees? Last edited: Apr 18, 2023

Thanks. I understand your suggested approach would work well if we want to do that every year. What if it is a one-off event? I.e., in general we would want to disburse dividends in the same 65/35 ratio as ownership, but this particular year, as an exception, we want do disburse them 50/50.