Recent content by ecommerceoffshore

@TheCryptoAnt I technically live in CY in that I have a lease there all year but I spend 70 days there and the rest it’s empty. @solas fwir enough and I will with the returns and tax R certificate but still skeptical

Hi all, anyone know of good low / no tax countries with low / no min stay requirements for a tax residency certificate? Currently in CY at 60 days, but proving to have an issue with US LLC paying me with 0 tax because I can only get 0 tax from dividends and US LLC cant pay dividends. I like...

Hi all, I am wondering if, say, I live in Cyprus and have tax residency in Cyprus, and a CY compnay that pays 12.5% tax there, if Canada were to try and challenge me in the future, since I dont actually have payable tax in CY (only the company does at 12.5% and I pay 0 dividend tax), then they...

Hi all, can anyone say why its beneficial to live in a country with a DTA as originally from Canada, wihtout mention of double taxation itself? Like, if I live in Panama for example, and Canada sees this on my non resident returns (I own Canadian real estate), could they easily just deem me as...

Hi all, does anyone know if the USA has / enforces hybrid mismatch rules where if you don't pay tax as a NRA with an LLC in a foreign country, they'll charge you tax? I am wondering if I pay 0% tax with my LLC as a non resident alien of the USA, if they have mismatch rules which demand the LLC...

Hi all. Anyone know of a good 0% or territorial country where one can make a shell corporation own a non ETBUS E-commerce US LLC, then the US LLC pays this corp, which then distributes to a Cypriot Non Dom the dividends? I'm wondering on recommended countries to do this where the tax is zero...

@cyprus123 @CyprusBusiness @CyprusLaw @CyprusLawyer101 @CyprusNonDom why not just have a 0% or territorial country corporation own the US LLC, then the US LLC pays this corp, which then distributes to you dividends? If so, does anyone have recommended countries to do this where the tax is zero...

@CyprusLawyer101 perhaps I am. I thought management and control is a test of whether a foreign corporation is controlled and managed within a given country.

@CyprusLawyer101 I thought this could only apply to CY tax resident companies controlling foreign companies, and CY has no governing law regarding tax resident natural persons controlling foreign companies

@CyprusLawyer101 you mean CFC rules? As relevant to Cyprus, or the offshore company like Panama or another? As I udnerstand it, Cyprus CFC rules only apply to Cypriot businesses and not natural persons.

@Marzio I understand this fact, although even this is unclear about how each country interprets the US LLC. You're saying Cyprus tax law specifically acknowledges the transparency of an LLC? Some countries dont know what to do with the transparent structure apparently and therefore still treat...

For non EU national, how do you get around being on a visitor visa, and also holding office in a CY company? The visitor visa doesnt allow for work, but holding office like director or secretary is apperently considered a "job". As I understand it, to hire yourself in your company and pay...

Hi all, I live in Cyprus and have run into a rule for the 60 day rule where my accountant can't get me the status because I am required to hold office in a Cypriot company, and it's considered a "job" where I am living in Cyprus on a Visitor's Visa where I am not allowed to work. Anyone have...

Hi all, I am a Canadian citizen living in Cyprus under non dom status. Wondering if I do Ecommerce in USA with an LLC, where the LLC is 100% owned by a 0 tax offshore corp, if the structure could work such that the LLC distributes $$ to the offshore corp which isnt taxed, then I collect...

@CyprusLaw could you just have the LLC 100% owned by an 0 tax offshore shell corp, say in Panama, and then have that corp pay the Cypriot non dom dividends? If so, are there any countries which are preferable to make sure its easy enough to do with banking, and doesnt raise any eyebrows...