Did you try Panama Private Foundation as Holding?
- Thread starter SaaS
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Unless you have at least $1M - forget about it. Using a US LLC with a foreign legal entity as a member is also not a good idea due to the branch profits tax. However if you insist on using a US LLC I think this could be solved by using a trust instead of a foundation.
Look into UAE - it might be better to just set up everything there, with substance and local banking of course. So an ADGM/DIFC foundation + FZCO. An alternative would be︀ to have an independently owned OpCo which would lease assets from a foundation, although I'm︁ not sure if that would work in practice.
What's your tax residency btw? As Martin︂ said a few months ago all structures in 2023 need substance, however a foundation is︃ a problem by itself as some countries don't recognize foreign foundations at all. So it︄ is not only a tax but also a legal issue. And if you need to︅ go with a Liechtenstein foundation (due to DACH residency for example) costs can go up︆ quickly.
e.g. https://blumgrob.ch/wp-content/uplo...foreign-family-foundations-in-Switzerland.pdf
Foundations also differ between jurisdictions which needs to be taken into account︇ of course. See this for example: https://www.ius.uzh.ch/dam/jcr:2c894a3c-b7d7-4f9d-ac0d-d514a3349dbb/Noseda_Common Law Foundations - A Successful Experiment.pdf
https://www.linkedin.com/pulse/comparison-foundations-difc-adgm-rak-icc-hanafin-tep-chartered-mcsi/
Look into UAE - it might be better to just set up everything there, with substance and local banking of course. So an ADGM/DIFC foundation + FZCO. An alternative would be︀ to have an independently owned OpCo which would lease assets from a foundation, although I'm︁ not sure if that would work in practice.
What's your tax residency btw? As Martin︂ said a few months ago all structures in 2023 need substance, however a foundation is︃ a problem by itself as some countries don't recognize foreign foundations at all. So it︄ is not only a tax but also a legal issue. And if you need to︅ go with a Liechtenstein foundation (due to DACH residency for example) costs can go up︆ quickly.
e.g. https://blumgrob.ch/wp-content/uplo...foreign-family-foundations-in-Switzerland.pdf
Foundations also differ between jurisdictions which needs to be taken into account︇ of course. See this for example: https://www.ius.uzh.ch/dam/jcr:2c894a3c-b7d7-4f9d-ac0d-d514a3349dbb/Noseda_Common Law Foundations - A Successful Experiment.pdf
https://www.linkedin.com/pulse/comparison-foundations-difc-adgm-rak-icc-hanafin-tep-chartered-mcsi/
I think this one
https://taxsummaries.pwc.com/united-states/corporate/branch-income
But is this an issue for a US LLC that is not engaged in a US trade or business?
https://taxsummaries.pwc.com/united-states/corporate/branch-income
But is this an issue for a US LLC that is not engaged in a US trade or business?
Yes, probably less tax risk than holding the US LLC personally and more flexibility in general as you can control when to get your much salary/dividends/profit in your personal account. But what about the branch profit tax problem?
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