Recent content by 22kay

What is your intent with this corporate structure? What are you trying to solve? Tax planning? Future handover to your children? Big bang exit in x years? Maximizing investment funds? Or a mix of these? Etc... Once you know that, it will make it easier to decide how to setup the structure. Just...

Anybody heard about these: Business Account for Global Payments | OneMoneyWay Any experience, good or bad? Would like a bankgiro account with them, if possible.

"For income tax purposes, an LLC with only one member is treated as an entity disregarded as separate from its owner, unless it files Form 8832 and affirmatively elects to be treated as a corporation." Link to IRS...

How can it be disregarded? If an LLC elects to be taxed as a C-corp it is not a disregarded entity. It will be taxed twice, first on the federal level and then on the individual level. Still don't understand why you would do this...?

Yes, this we do agree on :) . Just don't call it a dividend when it comes to LLC's, not to confuse the wording and meaning of a dividend from a "stock company", corporation. Regarding LLC distributions to other countries I've never done it this way and I have no idea if that works. Perhaps it's...

I am very much aware (personal experience) of the LLC elected as a C-Corp for tax purposes, I thought I already made that clear in my posts? What is also clear is that an LLC does not issue stocks and distribute dividends. An LLC is owned by members and they make income on shares of the profit...

Kind of not...the dividends would be profit distribution on a members share (but for an LLC it is not fixed parts like stock, it is a fixed part of the entire profit (profit share - not really a dividend). From an IRS point of view they will treat the profit distribution as part of your income...

As @Xshore is saying, the US LLC does not have shareholders, it has members and thus no dividends (share->dividends, no shares->no dividends). If you use the pass-through entity and in your case setup as sole proprietorship (one owner) any profit from your US LLC will be declared on your...

You can move out of EES/EU, make your tax returns in Sweden and the other tax residency country for a few years (5-7), and Sweden will release you from taxing in Sweden. This works even if you own the stocks in a Swedish AB and sit in the board. During the time you are a tax resident in Sweden...

Anybody done the (Panamanian) residency through employment by own company? Pro's/Con's? Any experiences? Anybody knows about the total price once having the permanent residency card in hand?

There is no tax in US if you receive inheritance from another country. But there is an informational return to file if you receive more than $100K in value.

Sorry for becoming silent, I just haven't proceeded. The actions are like a two-part rocket, simplified: 1) register and move ownership 2) pay out dividends So, first to register an entity in EU is pretty straightforward, if you don't know the language/process there are a lot of companies that...

Did the CPA elaborate on choosing either to be taxed as C-corp or pass-through for the LLC?

If the LLC is setup as passthrough as a single foreign member and the actual (100%) work/service is not done within USA borders then US IRS will not care to tax the LLC member or the LLC entity. But of course, as you say, Spain, and I believe most jurisdictions in EU whereever the LLC member...

If LLC is taxed as a C-Corp in USA, LLC is paying CIT on the profits. If LLC is taxed as a disregarded entity then the profits and losses are pass through to the members (yours) tax return (eg. no CIT). If you are US tax resident there is additional self employment tax to be paid. If you are not...