Recent content by 22kay

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...

Not really. The answer from the tax lawyer raised more concerns and questions then answers and it would be more to my specific situation. So, no further move from my side at this point.

Yeah, have done, will update once I receive an answer.

That is up to each tax treaty, how much of the dividend that would be taxed when paid out to a person (not company). In the case of Sweden->Estonia, Sweden would withhold 15% tax. Same for Cyprus, Malta and Ireland. For Portugal it seems to be 10%. I only went through the Swedish tax treaty with...

The new directive, as referenced by the EU, will have a "filtering system" with 3 levels. 1. is the companies income passive, eg. through dividends, etc 2. is a majority of the transactions cross-border 3. is management and administration outsourced In my case the 1 and 2 are yes. The 1 is of...

Thanks, good to know. Sometimes that can be a good thing, sometimes not.

https://taxation-customs.ec.europa.eu/news/commission-proposes-end-misuse-shell-entities-tax-purposes-within-eu-2021-12-22_en https://taxation-customs.ec.europa.eu/taxation-1/unshell_en @Martin Everson , I assume this would be the actual issue, you were warning about? Not sure why it is called...

Bingo :)

So if a dividend is received by a natural person in a low tax jurisdiction (not taxed on foreign income) from the Estonian holding company, it should be taxed 7%? Let me rephrase: So if a dividend is received by a natural person in a low tax jurisdiction (not taxed on foreign income) from the...