EE Holding & US LLC (or any pass-through / zero-tax entity)

[justanotherguy]

Didn't want to hijack this thread, and many others where EE was touched, but then skipped...
https://www.offshorecorptalk.com/th...e-qualifying-income.41414/page-26#post-266273
But many people mention Estonia as a Holding, along with US LLC, where EE would be PE.

We want to try this structure, and UBO is a EE employee & director, but he lives in another EU country.

1. Is the best way to have US LLC under a person (not the EE holding) because of branch profit tax?
2. If under a person, isn't US a disregarded entity and dividends from there would be taxed on a personal level in EE? Even if sent to EE Holding. Or am I missing smth...
3. Aren't dividends from US LLC to EE Holding will be taxed in EE because no tax was paid in the US? I believe it's 7% minimum

 

[offshore8]

justanotherguy said:
Didn't want to hijack this thread, and many others where EE was touched, but then skipped...
https://www.offshorecorptalk.com/th...e-qualifying-income.41414/page-26#post-266273
But many people mention Estonia as a Holding, along with US LLC, where EE would be PE.

We want to try this structure, and UBO is a EE employee & director, but he lives in another EU country.

1. Is the best way to have US LLC under a person (not the EE holding) because of branch profit tax?
2. If under a person, isn't US a disregarded entity and dividends from there would be taxed on a personal level in EE? Even if sent to EE Holding. Or am I missing smth...
3. Aren't dividends from US LLC to EE Holding will be taxed in EE because no tax was paid in the US? I believe it's 7% minimum
Click to expand...

Have you figured out How this works and Whats the Best way to structure US LLC and Estonia OU company? Thanks

 

[Don]

justanotherguy said:
1. Is the best way to have US LLC under a person (not the EE holding) because of branch profit tax?
Click to expand...

Possibly

justanotherguy said:
2. If under a person, isn't US a disregarded entity and dividends from there would be taxed on a personal level in EE? Even if sent to EE Holding. Or am I missing smth...
Click to expand...

No. Estonia regards US SMLLC as a PE.
Only profits arising from Estonia will then be taxed in Estonia, and only on deemed distributions (e.g. when money is taken out from the PE).
Depending on the structure, the company might have a registered PE that is not considered a PE from tax perspective, so the profits will not be taxed in Estonia.