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Recent content by flyinglow

  1. flyinglow

    Defining Remittance in Thailand & Living From Offshore Company

    In the case of the old rules - 6 months in Thailand + tax treaty tie-breaker will cover it In the case they bring in new rules, when applying the factor tests I'm not a resident anyway. No economic connection, no kids going to school there etc. Only one I tick is having Aussie passport No...
  2. flyinglow

    Defining Remittance in Thailand & Living From Offshore Company

    Hey guys, Have been toying with the idea of changing my country of residence from Cyprus to Thailand for a variety of lifestyle and taxation reasons. I understand that there's a lot of uncertainty about the recently announced changes to their tax system, however wanted to ask a couple of...
  3. flyinglow

    Best offshore jurisdiction for collecting AdSense income?

    Another consideration for people earning royalties through adsense that I just wanted to add. "A C with 60% or greater total yearly $ passive revenues (royalty income) represents a personal holding company ("PHC") for US tax purposes. A PHC has restrictions on accumulating profits. (1) So, a...
  4. flyinglow

    Incorporating in a US DTA Country [Cyprus], but not actually residing there

    I can't seem to DM you, but unfortunately for the Cyprus structure, it looks like the LOB provisions are pretty clear and would exclude from benefits if I were a tax resident of Dubai.
  5. flyinglow

    Incorporating in a US DTA Country [Cyprus], but not actually residing there

    The profits would be taxed in Cyprus, so that wouldn't be an issue. The only big problem is if I'm not a tax resident of Cyprus, my company would fail the base and erosion test and therefore be unable to claim tax treaty benefits. I don't want to reside in a country where it looks like I won't...
  6. flyinglow

    Incorporating in a US DTA Country [Cyprus], but not actually residing there

    Thanks for your response. I was under the impression the Cyprus company can't claim benefits due to me (the sole shareholder) residing in a different country. Is this true?
  7. flyinglow

    Incorporating in a US DTA Country [Cyprus], but not actually residing there

    A lot of the income are from US viewers and since 6 months ago, Youtube has required creators to fill in a W-8BEN-E Form otherwise have 30% of the revenue generated from US viewers withheld. This would equate to 30% of most of our revenue.
  8. flyinglow

    Incorporating in a US DTA Country [Cyprus], but not actually residing there

    Hi guys, I incorporated my Youtube company in Cyprus a couple months ago with the intention of residing there and claiming the benefits under the DTA with the US. Due to recent events in Europe, and the fact that Cyprus always follows along, I don't think it would be tenable for me to stay in...
  9. flyinglow

    Offshore Structuring in Cyprus & Dubai

    Hello, I have figured out one step of the puzzle in that I will be setting up my active income business in Cyprus as well as my individual tax residency. However my active business is at higher risk of future litigation, and for that reason, I do not like to hold that much funds in this company...
  10. flyinglow

    Question Escaping Australia - Controlled Foreign Company Laws and living as a Nomad

    After doing a lot of research today, I have found that the current proposal would actually work quite well. Could you let me know if I am missing anything? It says that in order to break ties with Australia and if you were a tax resident the previous financial year, you would need to satisfy...
  11. flyinglow

    Let's Talk About Africa

    I personally think Africa is one of the most underrated places on Earth. I'm not talking in a touristic or cultural sense, but rather economically. First off, being of South African descent, I understand the multitude of problems that underlie a lot of African nations. This traditionally makes...
  12. flyinglow

    Question Escaping Australia - Controlled Foreign Company Laws and living as a Nomad

    Thanks heaps for the reply. I still have hope they'll take a while to implement this, and praying I don't get dragged back into their net hahaha. Yep, I totally agree on your second point. Breaking ties now could prove to be the best thing. No adhesive tax plus the relaxed residency rules will...
  13. flyinglow

    Question Escaping Australia - Controlled Foreign Company Laws and living as a Nomad

    In the case that I do get caught in a sticky residency, would this mean that I would be paying tax to both Australia and Cyprus due to no DTA? If this is the case, this is especially worrying. I really hope they do allow for a transition period. Are there any resources you could direct me to...
  14. flyinglow

    Cyprus Company + Non Dom

    Hey there! I am in the exact same position where I have around 15-20 contractors working around the world and I run multiple Youtube channels. Will be moving to Paphos, Cyprus next year. Which city are you thinking moving to? In regards to your strategy, I'm sure other members on the forum are...
  15. flyinglow

    Question Escaping Australia - Controlled Foreign Company Laws and living as a Nomad

    Well I figured I would put the advice up now for any other Aussies who end up stumbling upon this thread . 1) Since the border re opening, you will only need an exemption from DHA if you are unvaccinated. 2) For those of us unvaccinated, your best bet is to apply under the 3 months category on...