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The keyword here is automatic. I'm not saying it does not happen, but upon request by a foreign treaty country, through an EOI Request, to the IRS's Exchange of Information Office, it could happen. Foreign tax offices with treaties with the US will have to open EOI Requests, and in cases like...

If you need serious advice, I can introduce you to American international taxation experts, some individuals even have a lawyer and a CPA license at the same time. Taxation in any serious country is a complex issue, the key is you need to seek advice from the right person.

:) thank you

Branch Profit Tax are only applicable when the US LLC is engaging in USTB and has ECI. As for the taxation from the home country for services rendered overseas, 90% of the cases are that these will be taxable, so that is why taxation consultation on both sides is needed.

US is not in the CRS, they will not exchange information automatically. On IRS forms, you put in your ITIN number normally (if there's a need for that) and the ITIN is a tax number awarded by the US govt. Sometimes the ITIN is not even needed, just a random number would do (like the Form 5472)...

Nomad capitalist is not necessarily bulls**t, it is just that his videos do not have any actionable nor concrete insights.

Bulgaria has a tax treaty with the US. You can claim for tax treaty position, and not worry about the ETBUS issue anymore as long as you dont have a permanent establishment and dependent agent in the US. As for Bulgaria, it will depend on how Bulgaria will see the LLC, some countries see it as...

JustAnotherNomad is correct, although I would like to point out that although the SMLLC or Partnership is a disregarded entity, the IRS will see if the Disregarded entity is engaging in USTB and have ECI, it is a bit nuance, but generally, it is correct. As an NRA, having a pass-through entity...

complete nonsense. this is not how it works. tax treaty is mainly to avoid double taxation. Look for taxation on Non-resident aliens on IRS website. Incidentally, we have an article yet to be published that touches upon this, if you are interested i can send you a preview.

If you are looking for non-US taxation advice, OffShore Citizen on youtube is quite good

The definition of etbus could be ambiguous, but if you are worried, and your country has a tax treaty, you could file for tax treaty claims.

Yes Stripe is easy for US LLC owned by Non-resident. They are certain things to look out for, but its doable. We can help you with the process, see my signature

I don't think leaving a certain number in the bank to get taxed at a minimum is a good idea, given that this will definitely involve questionable methods as well. The US clearly has transfer pricing rules. From what you described, it is highly likely you could pass as an NRA with no USTB and...

As long as your SaaS software adheres to GDPR and your company does not come from a tax haven country, it won't be a problem for your European clients.

Yes, you are correct, US Paypal receiving from US Paypal customer is the cheapest.

Yes, I know what you wrote. We never tried to use a US IP to apply for Paypal. If you are using a normal vpn, it is very likely the IP will be flagged as a datacenter IP, which defeats the purpose of "masking" the origin. If you really want to be 100% safe, you should use a residential ip vpn...

You don't need to turn on your VPN to open a US PayPal account when you are outside of the USA

There are no "dividends" in LLC, only distribution of profits. But it also depends on your host country would categorize it.

so 1 Italian company costs you 290 UK companies. Incredible

If your US LLC is engaged in a US Trade or Business and has US Source income effectively connected to it, then you will need to pay US Federal taxes on your profits. LLC does not have the concept of shares like corporations.