Jurisdiction that do not share Beneficial Owner information in a public register

[dash]

I'm looking for a jurisdiction with a high level of privacy where I can incorporate a limited holding company that do not publicly share any information about the shareholders and ultimate beneficial owner (UBO) in a public registry.

I'm fine with submitting the UBO to financial institutions and I will also include the company in my personal tax return, I just don't want that my name is searchable in any public register or database.

The company would be used only for holding my financial assets and trading through an investment broker.

I was researching the Wyoming LLC with C-Corp election, but it seems to be way too bureaucratic as a C-Corp and also I don't like the additional 20% Personal Holding Company Tax which I would have to pay.

My requirements:
- not a blacklisted jurisdiction, it must be easy to open a bank account & broker account
- reasonable tax rate (around 15-20% is fine)
- not a pass-through vehicle
- no public disclosure of UBO and shareholder names
- not too bureaucratic

Are there some options for my needs?

Last edited: Feb 4, 2024

 

[koohl]

I believe if you want to do something wise and you are afraid of revealing your identity behind a company, then you should check out Mentor Group Gold and read through the sea of endless information you can find there. For example, the article below:
https://www.offshorecorptalk.com/threads/you-need-a-real-address-and-director-for-a-uk-ltd.43463/
If you don't want to do that, then I would recommend you to find a country where you can establish a company where the taxes are really low, then set up an office there and find a way to hire someone for something there. Then you can sleep reasonably peacefully for the next 5 years until the world changes again and the aggressive tax authorities have come up with new invented schemes to disprove the legitimacy of your setup.

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[Alexmorgan]

Go holding LLC in wyoming

It will be easier and no name shared to public at all

 

[koohl]

Alexmorgan said:
Go holding LLC in wyoming

It will be easier and no name shared to public at all
Click to expand...

for now!

Toggle signature
My Journey to successful card processing for Replica, IPTV, Adult and Gaming business.
I keep my journey in the closed forums in Mentor Group for less saturating methods.
Please understand that I don't sell any services or do consultancy, you don't need to contact me about that!

 

[dash]

Alexmorgan said:
Go holding LLC in wyoming

It will be easier and no name shared to public at all
Click to expand...

I live in a high tax country and I want to stay here for now, because of the highly paid job which I have.

If I understand it correctly with the Wyoming LLC, I have two tax regimes to choose from -- by default it's taxed as an S-Corp (disregarded entity), which means no US tax and all the profit is taxed in the country of my residence with a marginal tax rate (I want to avoid this). However, I can submit IRS Form 8832 to elect a C-Corp taxation (non-disregarded entity) and in that case there will be 21% US CIT plus 20% Personal Holding Company Tax in the US on retained earnings.

But that sounds ridiculously high to pay 21%+20% tax in the US, plus then pay another personal tax in my country when I distribute the dividend (in case of C-Corp). When it's taxed as an S-Corp, I can't keep the retained earnings in the company to accumulate and I would also have to pay each year around 40% due to my high marginal tax rate. Am I missing something?

Last edited: Feb 4, 2024

 

[ilke]

dash said:
But that sounds ridiculously high to pay 21%+20% tax in the US, plus then pay another personal tax in my country when I distribute the dividend (in case of C-Corp). When it's taxed as an S-Corp, I can't keep the retained earnings in the company to accumulate and I would also have to pay each year around 40% due to my high marginal tax rate. Am I missing something?
Click to expand...

You're not missing anything, but that is the truth. You will not be able to avoid taxes (unfortunately). Seeing as you're in a high-tax marginal tax rate country, I would assume that it does not have territorial taxation. Most often, these high-tax countries will have laws that make any company with you (a tax resident) as the director and somebody involved in the management into a tax resident of your country.

You will not be able to legally avoid paying tax in your jurisdiction even with a 0% tax company due to CFC and PE rules; you have to do some searching and find out the specifics for your country. Illegally, you might be able to open a company in a secretive jurisdiction, but you are still at risk of banks reporting to your country. I would recommend not relying on this - because you won't be safe forever.

In a lot of cases, you are much better off registering the company in the country you live in and spending the money, using deductions and incentives, etc.

It definitely depends on the place you are a tax resident, though. There are some countries that will not have applicable CFC rules if the offshore company is, for example, not in a blacklisted jurisdiction or pays 50% of what it would pay in your jurisdiction already. PE might still cause it to be a tax resident, regardless.

 

[dash]

ilke said:
You're not missing anything, but that is the truth. You will not be able to avoid taxes (unfortunately). Seeing as you're in a high-tax marginal tax rate country, I would assume that it does not have territorial taxation. Most often, these high-tax countries will have laws that make any company with you (a tax resident) as the director and somebody involved in the management into a tax resident of your country.

You will not be able to legally avoid paying tax in your jurisdiction even with a 0% tax company due to CFC and PE rules; you have to do some searching and find out the specifics for your country. Illegally, you might be able to open a company in a secretive jurisdiction, but you are still at risk of banks reporting to your country. I would recommend not relying on this - because you won't be safe forever.

In a lot of cases, you are much better off registering the company in the country you live in and spending the money, using deductions and incentives, etc.

It definitely depends on the place you are a tax resident, though. There are some countries that will not have applicable CFC rules if the offshore company is, for example, not in a blacklisted jurisdiction or pays 50% of what it would pay in your jurisdiction already. PE might still cause it to be a tax resident, regardless.
Click to expand...

I would not be in the managing board of the company. I'm aware of the effective place of management rule, that would trigger the corporate residency. I would be only the beneficial owner and the shareholder of the company, the actual management decisions would be done by a manager in other country.