I'm not sure how is any of this relevant for the OP??
He wants a MNE company. Then it's 15% cit + 15% cgt. How is this avoidable?
Wyoming LLC vs UK LLP
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I'm not sure how is any of this relevant for the OP??
He wants a MNE company. Then it's 15% cit + 15% cgt. How is this avoidable?
Wyoming LLC may be the best in your situation and now things have changed in the US. You get a simple & low cost setup.
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Only the early bird catches the worm.
Yes i chatted with the local lawyer here the other week and he did not see any issues with that arrangement either. I was hoping to chat with my UK accountant contact to get his perspective but he has gone all quiet for the time being. We will keep investigating, it is not something we need right now but most likely will be in the next 6 months or so. Indeed, Wyoming seems to be the simplest as long as you keep up with your reporting duties but then that is what the agent/accountant should be on top of 🙂
You want also to speak with @James Turner about the UK LLP it can't harm to get more input before you go on.
Have you spoken to them recently? I'd be interested to know if it's actually possible to stay under the radar there.
Yes, I speak with them often and have asked again, no one contacted them while they were living there. They moved out last week, and the deregistration process was easy and didn't require providing any information about where they went.
According to him, it's one of the few places where you can live for almost two years without paying taxes and then disappear into thin air permanently.
According to him, it's one of the few places where you can live for almost two years without paying taxes and then disappear into thin air permanently.
Without paying what kind of taxes? Local? Many other jurisdictions do not enforce cfc rules, many do not even have them. MNE is not an outlier here?
we are way off topic, I know... the guys I knew didn't pay any taxes at all while they stayed in Montenegro, that was just my point.
have been in touch with them a few times, they are easy to work with.
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Only the early bird catches the worm.
I tried reaching out, but had some trouble getting through to the right person using the contact info on their website!
I have a call with my UK accountant soon to explore this option further. His only concerns were, in his words,
"that an LLP should be set up for an active purpose of making a profit. Whether this can be by the LLP taking a cut to justify its existence, I'm not sure.
Just one more thing, we're all conscious of shifting funds around jurisdictions so you will need (and am sure would be anyway) to be able to demonstrate transparency and proper purpose here"
I guess one could run all the expenses through the LLP and then just bill the profit out to the Montenegrin entity.
Will hopefully know more soon and report back.
"that an LLP should be set up for an active purpose of making a profit. Whether this can be by the LLP taking a cut to justify its existence, I'm not sure.
Just one more thing, we're all conscious of shifting funds around jurisdictions so you will need (and am sure would be anyway) to be able to demonstrate transparency and proper purpose here"
I guess one could run all the expenses through the LLP and then just bill the profit out to the Montenegrin entity.
Will hopefully know more soon and report back.
But would you even have to bill the profit out? If the UK LLP was owned by a Montenegrin entity, wouldn't all profits be automatically attributable to the Montenegrin company anyway?
Exactly what i thought, hence a pass through entity. Maybe he is misunderstanding me or being too conservative. I will know more when i speak with him.
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