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  1. S

    Treatment of an US LLC if there's no tax treaty

    that's good news for you. may i know which country?
  2. S

    Treatment of an US LLC if there's no tax treaty

    of course the treaty does not cover POEM nor CFC. CFC and POEM are defined at the tax code of each country
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    Treatment of an US LLC if there's no tax treaty

    CFC and POEM are different. CFC is mostly for passive shareholding and POEM is for active management of the company.
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    Treatment of an US LLC if there's no tax treaty

    Legally speaking, since you are operating the US LLC from your home country, this will trigger the place of effective management rule in most of the countries; you will need to treat this US LLC as a "local" company. Bjt you can argue your managers are outside of the country so the management...
  5. S

    Treatment of an US LLC if there's no tax treaty

    tax treaty doesn't normally how the LLC will be treated in the other country. From the US taxation point of view, it is regarded as pass-through. Of course this is assuming you are not engaging and US Trade or Business and has effectively connected income to this USTB. For the home country, it...
  6. S

    Anyone got EIN recently? How long does it take?

    We do it in 7-8 business days legally. The ones who advertise that they can do it in one day are doing it illegally. They use an american to be the Responsible Party. Some banks might notice that, some won't. And you need to file another form to change it back to your name which itself takes...
  7. S

    Business bank account for international in & outgoing transfers. [

    Sadly I'm not so well-versed with Estonia. Maybe you should setup a US LLC in front of your Estonian company. Your Estonia company could be the holding company of the US LLC. Just saying though. Hope other members could offer more insight into this.
  8. S

    UAE + UK LLP/US LLC setup questions

    If you are issuing invoices to European companies some of them might not accept a Dubai Company invoice. Generally, it is better to use Dubai as a holding company rather than the operating company
  9. S

    Business bank account for international in & outgoing transfers. [

    where's your tech company incorporated? different jurisdictions have different choices of EMIs and banks
  10. S

    UAE + UK LLP/US LLC setup questions

    The reason to have a US LLC in front of the Dubai company is you can have access to Stripe Paypal Transferwise and other popular services for US companies and the LLC does not have any taxes if you fulfill certain criteria
  11. S

    Wyoming / New mexico tax filing Q...

    You will need to file the Form 5472 no matter what. You can get away without hiring an accountant, but you need to keep adequate records for 1) filling the form 5472 and 2) answering to IRS in case of audits. You can read more about them in our guide here...
  12. S

    USA LLC card personal use

    even if corporate veil is pierced, it will still not change the fact that he is a non-resident alien who's not subject to tax.
  13. S

    Delaware LLC Payment Processor without TIN

    You don't need an ITIN to get Stripe at all
  14. S

    Delaware LLC + offshore bank account

    You must be mistaken, I'm not replying to you.
  15. S

    Delaware LLC + offshore bank account

    Yes, remote opening is possible. US is not in the CRS, they don't automatically share the information with other jurisdictions. You can talk to us at Register U.S. Company Remotely as a Foreigner (No Visit Needed). We will guide you through the process
  16. S

    Delaware LLC + offshore bank account

    Getting an offshore bank account for your Delaware LLC could be a challenge. Why not just use a US bank account?
  17. S

    Delaware LLC Payment Processor without TIN

    Why not just use stripe if business is not high-risk
  18. S

    LLC in US owned by a single-member resident in Panama, no ETOB but still owning taxes?

    no problem. PMed you the article
  19. S

    Where's a suitable place (minimal reporting) to incorporate if no privacy is needed?

    The issue of taxation of non-U.S. persons is actually not that complicated. If your country has a tax treaty with the US (which is the case for most European countries), everything is even clearer It is just that a lot of US accountants are US-centric, they are not familiar with international...
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    Where's a suitable place (minimal reporting) to incorporate if no privacy is needed?

    If you are qualified (no Permanent Establishment or not ETBUS) to pay no taxes in the US, the only thing you need to file is Form 5472, which is a very simple document to file to the IRS.

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